Compliance

Toward strengthening the compliance structure to adapt to expanding and diversifying business models

SMFL is promoting measures to ensure the compliance first culture and to establish a compliance structure suited to the characteristics of each business so that we can establish business foundation.

Overview of SMFL compliance policy. Section 1: Formulation of Compliance Policy, explaining the principle of acting in good faith and complying with laws. Section 2: Definition of Compliance, covering adherence to laws, regulations, and social norms. Section 3: Five Compliance Policies—Do the Right Thing, Risk Ownership, Comply with Laws and Rules, Speak Up, and Respect for Human Rights—with brief descriptions for each.

SMFL Group Compliance Policy

Structure for Promoting Compliance

SMFL established the Compliance Committee. Chaired by Managing Executive Officer in charge of the Compliance and General Affairs Department, this Committee in principle meets twice a year and discuss various compliance-related measures.
On an organizational unit basis, each department manager is responsible for compliance. A Compliance Officer is assigned to each department to assist the general manager in ensuring that all employees are fully aware of the laws, regulations, and internal rules related to business operations.
Unit Compliance Officers are assigned to each business unit to collect and collate information on laws, regulations, and industry trends suited to the characteristics of each business unit, and to provide guidance and support to general managers and compliance officers under relevant business unit.

Diagram of the compliance structure. At the top: Compliance Committee, followed by Compliance and General Affairs Department. Below: Unit Compliance Officer (UCO) with roles to promote measures suited to business characteristics and coordinate with department compliance officers. At the bottom: Each department with a Department Manager and a Compliance Officer (CO), showing responsibilities such as assisting the manager and preventing or correcting violations.

Promote Compliance Initiatives

As part of our annual plan, we are formulating a compliance program while working to foster a compliance culture, establish a risk management system, and share information among departments.

Items Description
Fostering a compliance culture Information dissemination, including messages from the President, and compliance sessions for all officers and employees (approximately 90% of domestic employees participated)
Instill a Compliance-first Culture
Compliance awareness survey results. In response to the question: ‘In your department, when actions required to achieve earnings and performance targets conflict with “doing the right thing,” do you think there is an atmosphere or culture that prioritizes “doing the right thing”?’ the share answering ‘I believe so’ or ‘To a certain extent’ was 91.6% in 2022, 94.7% in 2023, and 96.4% in 2024.

Fixed-point measurement of the degree of awareness toward a compliance-first culture using compliance questionnaires
Enhance the Risk Management System In addition to strengthening the risk management analysis of new businesses, we will work to entrench management systems through training and monitoring
Support the development of risk management systems at overseas locations and each department We are developing overseas locations and Group company systems suited to business characteristics while implementing compliance measures for new business ventures
Compliance personnel exchanges in each department Regular information sharing and the promotion of communication between organizations

Information Management

We have established our policy regarding the appropriate protection and use of customer information in our Privacy Policy.
Details regarding management systems are specified in "Handling of Customerʼs Personal Information."

Prevention of Bribery

We thoroughly disseminate information regarding regulations for preventing bribery to all officers and employees, as well as regularly monitor compliance with various regulations.

Cutting Off Relations with Antisocial Forces, and Anti-Money Laundering/Combating the Financing of Terrorism

We have established basic Group-wide policies on cutting off ties with antisocial forces and preventing money laundering and terrorist financing. Working in unison as the SMFL Group, we are taking steps to establish systems and respond appropriately.

Whistleblowing System

In order to self-cleanse where violations of laws or regulations are discovered and corrected at an early stage, and to protect whistleblowers, we have put in place an internal whistleblowing system.

Hotline Description
SMFL Alarm Line
(internal hotline)
Reportable matters:
  • Acts or facts that violate or are suspected of violating laws and regulations
  • Acts or facts that, if left unchecked, may damage the property interests or credibility of SMFL or its subsidiaries, the life, health, or property interests or credibility of customers or employees, or market order
  • Acts or facts that violate or are suspected of violating internal rules
SMFL Hotline
(external hotline)
SMBC Group
Alarm Line
Description of the system:
  • Same reportable matters as with the SMFL Alarm Line. Whistleblowing hotline that employees, etc. of Group companies can use if they hesitate to report to their own company’s whistleblowing system upon becoming aware of misconduct, etc. by officers or employees of their company
SMFG Accounting and
Audit Hotline
Reportable matters:
  • Improper or suspected improper accounting or auditing by SMFG or SMFG consolidated subsidiaries