Solicitation Policy

1. Policy for Sales of Financial Products

When recommending and conducting sales of financial products, SBI Shinsei Bank staff are governed by the following policy, which is designed to protect the best interests of our customers.

• SBI Shinsei Bank will recommend suitable financial products based on an understanding of the customer's financial conditions, investment experience and contract objectives.
• SBI Shinsei Bank will provide sufficient information, including risks and fees as well as advantages of the product, to allow the customer to make an informed purchase decision at the customer's own discretion.
• SBI Shinsei Bank employees will strictly abide by all related laws and regulations, and endeavor not to engage in sales activities at times or places inconvenient to the customer.
• SBI Shinsei Bank employees will provide impartial, unbiased advice on financial products, supplying the customer with clear and truthful information and explaining any associated risks.
• SBI Shinsei Bank employees are thoroughly trained to provide professional advice and to avoid inappropriate sales activities. The Bank has a comprehensive system of in-house supervision to ensure that these guidelines are strictly followed.

2. Guidelines for Soliciting Insurance Contracts

With regard to soliciting insurance contracts, our Bank hereby establishes the following Guidelines for soliciting insurance contracts and shall abide by them.

2-1. Soliciting insurance contracts

• Our Bank shall endeavor to perform soliciting activities in a fair manner as stated hereunder. In soliciting insurance contracts, we shall observe related laws, regulations and so forth and shall take necessary measures in order to enhance the convenience for customers as well as to protect their interests.
• Our Bank shall expressly indicate names of underwriting insurance companies of insurance products which our Bank introduces to customers.
• Our Bank shall always provide adequate information to customers according to their needs, including information on insurance products other than those offered by our Bank, so that the customer can select insurance product matching the customer's needs by the customer's own intention and judgment.
• Our Bank shall provide adequate explanation to customers so that customers fully understand the following points. Specifically, we will explain that it is not our Bank but the insurance companies that underwrite the insurance policy which the customer has purchased, and that the payment of insurance money etc. shall be made not by our Bank but by the underwriters. We will also provide explanations about the handling rules in case the underwriting insurance company with which the customer has concluded insurance contract goes bankrupt and other risks pertaining to insurance contracts.

2-2. Handling inquiries from and consultations with customers

• In the event that, due to violation of laws and regulations by our Bank's officers or employees, loss is incurred to a customer pertaining to solicitation of insurance, our Bank shall assume the responsibility of selling the product as the agent and shall handle the matter in good faith.
• Our Bank shall, in order to properly deal with inquiries from and consultations with customers, control and properly maintain details of explanations provided to the customer at the time of solicitation of insurance contract and minutes of discussions with customers after conclusion of the contract and so forth until expiry of the insurance contract with the customer.
• With regard to inquiries etc. from customers about details of insurance contracts which our Bank has solicited, we shall handle them properly even after conclusion of the insurance contract. Should you have any inquiries, please contact PowerCall at 0120-456-860.
• Complaints, consultations and so forth, if any, in relation to our solicitation activities for insurance contracts etc. should be addressed to our Customer Service Department at 050-3509-0075.
• Depending upon the contents of inquiries or complaints, the Bank may make a contact with the relevant underwriting insurance company. As for the inquiries about several procedures including an insurance claim payment procedure etc., the Bank may refer customers to the call center etc. of the underwriting insurance company.

3. Management Policy for Conflict of Interest (Outline)

3-1. General Rules

3-1-1. Purpose

SBI Shinsei Bank, Limited (hereinafter the “Bank”) has established the Management System for Conflict of Interest for (1) managing conflict of interest that may unfairly impair the interest of customers based on the Banking Act and the Financial Instruments and Exchange Act, and (2) managing conflict of interest that may impair the interest of customers in business operations that have set the highest priority in the “best interests” of the customers based on the Policy on Customer-Oriented Business Conduct publicly announced by the Bank at the Bank and its group companies (hereinafter, the “Group”). The Bank has also established Management Policy for Conflict of Interest which stipulates basic items of the Management System for Conflict of Interest.

Outline of this Policy shall be publicly announced as follows under the relevant laws and regulations, etc.:

3-2. Management of Conflict of Interest Based on the Banking Act and the Financial Instruments and exchange Act

3-2-1. Scope of the Group Companies

Group companies subject to the management for conflict of interest by the Bank based on the Banking Act and the Financial Instruments and exchange Act shall be as shown in a separate table.

3-2-2. Categories of Transactions Which May Involve Conflict of Interest and Examples

1. (1)Categories of Transactions Which May Involve Conflict of Interest

   Categories of transactions which may involve conflict of interest may include following: However, these categories merely show standards for making a judgment whether if there may be a conflict of interest or not. It does not necessarily mean that there is a conflict of interest if it is applicable to any one of the following. Also, additions or revisions, as required, may be made in future.

   1. i)When there is a conflict of interest between the Group and a Customer
   2. ii)When there is a conflict of interest between the Group's Customer and another Customer
   3. iii)When it is similar to i) or ii) above or when the interests of Customers are unfairly impaired in other ways

   The Bank shall take general circumstances, including any influence on the Group's reputation, into consideration to judge if conflict of interest is involved or not.

2. (2)Examples

   Examples of transactions which may involve conflict of interest shall include following and other similar transactions:

   1. i)Examples of Categories under i) (1) Above
      1. (a)When fundraising support services and/or advice, etc. on M&A are given with to a Customer who is in a conflicting or competitive relationship with principal investment of the Group
      2. (b)When advice, etc. are given for M&A to a Customer, to whom credit is given by the Group
      3. (c)When advice, etc. are given for fundraising support services and/or M&A to another Customer, who is in a conflicting or competitive relationship with a Customer
      4. (d)When advice, etc. are given to a Customer for fundraising support services and/or M&A and at the same time principal investment is made in the applicable Customer by the Group, assets are purchased from the applicable Customer and other transaction is carried out with the applicable Customer
      5. (e)When a Customer is assisted by the Group in the applicable Customer's financing and at the same time the Group intends to collect fund from the applicable Customer by means of fund raised through the Group's assistance
      6. (f)When the Group makes a principal investment in a Customer's assets, for which the Group has information
      7. (g)When a wide range of services are rendered to a Customer by the Group and it is intended to limit participants of a transaction to the Group companies
      8. (h)When securities issued or established by the Group or an interested party are recommended or sold to the applicable Customer, or when the Group incorporates the applicable securities into the applicable Customer's assets, of which the Group is entrusted with investment by the Customer. In addition, when the Group back-finances the applicable Customer who invests in the applicable securities
      9. (i)When the Group makes use of information of transactions with a Customer against the Customer's intention to pursue its own interests
   2. ii)Examples of Categories under ii) (1) Above
      1. (a)When advice, etc. are given with regard to fundraising support services and/or M&A to a transaction in which more than one Customer are in conflicting or competitive
      2. (b)When the Group makes use of information of transactions with a Customer against the Customer's intention to pursue interests of another Customer

3-2-3. How to Manage a Transaction Which May Involve Conflict of Interest(hereinafter, “Subject Transaction”)

If it is determined that a transaction is applicable to Subject Transaction, the Bank shall try to protect Customers appropriately through a selection or combination of methods below and other methods.

3-2-4. Management System for Conflict of Interest

1. (1)Establishment of a Division Responsible for the Management of Conflict of Interest
   1. i)Group Legal and Compliance Division, the Bank shall be the division responsible for the management of conflict of interest.
   2. ii)The division responsible for the management of conflict of interest shall not be instructed by the manager of any other business organization for details of operations and shall maintain its independence in operations of the management of conflict of interest.
   3. iii)The division responsible for the management of conflict of interest shall be responsible for the company-wide management system to specify transactions, which may involve conflict of interest, and to control conflict of interest.
2. (2)Responsibilities of the Division Responsible for the Management of Conflict of Interest

   The division responsible for the management of conflict of interest shall discharge following responsibilities in a position independent from divisions responsible for businesses at the Bank and the Group companies: When the division responsible for the management of conflict of interest gives an instruction to the Group companies or when the Group companies make a report to the division responsible for the management of conflict of interest, such an instruction/a report shall be given/made through the division responsible for internal management at the applicable the Group companies.

   1. i)To instruct divisions responsible for businesses at the Bank and the Group companies to implement appropriate management of conflict of interest with regard to the Subject Transaction as well as to specify the Subject Transaction.
   2. ii)To make semi-annual reports to the Group Compliance Committee and the Compliance Committee on transactions which may involve conflict of interest, as specified and managed. However, any item, which may have a considerable influence on the management or may considerably impair the interests of customers, shall be reported to the Group Executive Committee without delay.
   3. iii)To receive reports on the management status, etc. of conflict of interest for Subject Transactions, including Subject Transactions of the Group companies, on a regular basis or from time to time, to verify implementation of appropriate management and to review procedures and systems for the management of conflict of interest, as required.
   4. iv)If Customer's interests may be unfairly impaired, to instruct implementation of appropriate management of conflict of interest to divisions responsible for businesses at the Group, as required, or to review the Subject Transaction, etc.
   5. v)To give training, on a regular basis, to statutory executive officers and employees of the Group with regard to the management of conflict of interest on the basis of this Policy and management regulations for conflict of interest and to make sure that everybody appropriately understands about the management of transactions which may involve conflict of interest.
3. (3)Preparation and Conservation of Management Records of Conflict of Interest

   The division responsible for the management of conflict of interest shall record and maintain actions taken to appropriately ensure specification of Subject Transactions and their management and Customer protection for five years from the date of preparation.

3-3. Management of Conflict of Interest in Business Operations that Set the Highest Priority in the "Best Interests" of the Customers

the Bank will strive to manage conflict of interest indicated in "The Policy on Customer-oriented Business Conduct" and its "Action Plan" publicly announced separately.

End

Parent Financial Institutions, etc.
Subject to Conflict of Interest Management (As of March 1, 2024)

Company Name
SBI Holdings, Inc.
Japannext Co., Ltd.
SBI SECURITIES Co., Ltd.
SBI Insurance Co., Ltd.
SBI Sumishin Net Bank, Ltd.
SBI Life Insurance Co., Ltd.
SBI Asset Management Co., Ltd.
Rheos Capital Works Inc
SBI MONEYPLAZA Co.,Ltd.
SBI Investment Co., Ltd.
Other Parent Financial Institutions, etc.

Subsidiary Financial Institutions, etc.
Subject to Conflict of Interest Management (As of March 1, 2024)

Company Name
Shinsei Trust & Banking Co., Ltd.
Shinsei Investment Management Co., Ltd.
Shinsei Investment & Finance Limited
Showa Leasing Co., Ltd.
Shinsei Kobelco Leasing Co., Ltd.
APLUS Co., Ltd.
Shinsei Personal Loan Limited
Shinsei Financial Co., Ltd.
Diamond Asset Finance Co., Ltd.
Nissen Credit Service Co., Ltd.
Shinsei Corporate Investment Limited
Other Specially Permitted Business Notifying Person
Bank Agent having the Bank as its Principal Bank