Compliance

COMPLIANCE RELATED POLICIES

ORIX Group Code of Conduct and Ethics

The ORIX Group has established group-wide regulations on compliance, and has prescribed, while also endeavouring to promote, rules and codes of conduct that will keep directors, officers and employees of the ORIX Group adhering to the law, internal regulations, social norms, etc. Our policy expresses the standards of business integrity that we require from our officers and employees in promoting a culture of compliance and emphasizing high standards of ethical behavior at all levels within the organization to comply fully with all applicable Laws and Corporate Policies. The “Code of Conduct and Ethics” set out the basic principles of conduct to be observed by all the employees of ORIX Group.

Policy on Anti-Corruption

The ORIX Group and OLM maintains the highest ethical standards, adheres to all applicable laws, and endeavours to make sure that its officers, employees and representatives do not perform any acts over the course of business that may appear inappropriate. This policy prohibits improper payments, gifts or inducements of any kind to and received from any person, including officials in the private or public sector, customers, agents and intermediaries.

Policy on Anti Money-Laundering

OLM will not participate in any transactions related to revenue arising from any unlawful activities, transactions that finance terrorist activities or that are prohibited from being traded with by foreign governments. OLM policy on Anti Money-Laundering has been prescribed to comply with Standard Guidelines On AML/CFT issued by the Financial Intelligence & Enforcement Department in Bank Negara Malaysia and in compliance with the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001.

Policy on Prevention of Insider Trading

This policy has prescribed the basic matters required for the management of insider information, etc. obtained by officers and employees of the ORIX Group and OLM over the course of their business, for regulating the trading of shares, etc. as well as the matters for officers and employees to adhere to, and endeavors as a matter of course to prevent insider trading and other unfair purchases and sale transactions.

Policy on Prevention of Conflicts of Interest

The policy has prescribed ORIX Group’s standard for avoiding conflicts of interest, and in the event of an officer or employee of ORIX Group faces a situation where there is a business-related conflict of interest, or suspicion of such a conflict of interest, the ORIX Group and OLM endeavors to ensure that this is handled appropriately.

Policy on Giving and Receiving of Gift and Hospitality

The policy has prescribed the guidelines and minimum standards for giving and receiving of gifts and hospitality by employees to/from business partners, public officials and etc. OLM Group’s employees are prohibited from receiving or giving gifts and hospitality as a means to obtain unfair gain, and endeavours to conduct transactions with customers, third parties, public officials, etc. in a fair and transparent manner.

WHISTLEBLOWER POLICY

OLM believes in the conduct of its business and affairs in a fair and transparent manner by adopting the highest standards of professionalism, integrity and ethical behavior. Any actual or potential exceptions to the same would be a matter of serious concern of OLM. It is in the best interests of the organization that such exceptions are reported for taking timely remedial measures, immediate as well as long term. While OLM employees have always been expected to practice ethical behavior and be vigilant to any exceptions coming to their knowledge, the same responsibility is now being codified by way of a "Whistleblower Policy”.

 

The said policy has been developed to ensure that Compliance Concern is investigated confidentially, promptly and to give protection to persons who disclose Compliance Concern so that they report the same without any fear of victimization or adverse action.

 

Whistleblowing Hotlines have been established both internally and externally. An external hotline that uses external attorneys and specialists, as well as a reporting hotline that is independent of the executive level, have been set up, and by facilitating anonymous reporting, OLM is endeavoring to ensure that the system functions appropriately.

 

In addition, the policy which prescribes matters relating to the structure and operation of the whistleblowing system, prohibits the performance of unfair treatment on whistleblowers and persons who have cooperated with investigations, and in addition, obligates all officers and employees to, in principle, immediately report to their superior if they learn of a legal violation, rule violation, or act that is contrary to public order and morals, etc. or have a suspicion that this may be the case, and if reporting to a superior is difficult, to promptly notify the Whistleblowing Hotline.

 

After receiving a report, based on the management of the designated information recipient, a review committee and investigation committee, investigation and corrective action, etc. will be formed with careful management of the reported information and forthwith report the findings to the OLM Group Audit Committee. Appropriate action shall be taken against the offending Employee.