Management policy & Basic action policy

Management policy&Basic action policy

management policy

We set following 4 management policy for our business.

We aim to be an enterprise blessed with the most support of customers
We aim to be trustworthy company from the customer in the society
We do the best that we can to maximize our corporate value
We strive to improve the lives of our emplyee's circumstance

To carry out action guidelines, we set Basic Policy on Internal Controls & Basic Course of Action.

Confirm basic business policy of business partner

basic principle for our customer (abstract)

Customer is the most important matter for our business. We care our customer with first priority.
We express gratitude to our customers by good manner. We pay close attention to appearance & behavior so customers not make feel uncomfortable.
We will not supply any personal information to third parties, including their family.
We understand the importance of protecting personal information, so take necessary and appropriate measures to ensure the security of personal information,We understand that how customer understood and felt is important rather than how we explain.
We confirm that our explanation makes sense to them, if not we never put the blame on others. We respect our business partners & sales representative. They are very important for us regardless their business size. We understand our role and serve as a valuable partner for benefit for customers.
We believe we can be a valuable partner for every people who meet in daily life. We keep in mind that everyone who meets on a daily life may provide valuable contribution to our business; so we try to interact kindly and politely with anyone.

basic principle for our partners (abstract)

We conduct our business with accordance with applicable laws and internal corporate rules, and conduct in fair business manner; with partner client, We focused on long-term business relationship rather than short time period for build win-win relationship with business partners.
We shall maintain in confidence and not disclose Confidential Information. We select our partner client, sales representative by evaluating their business stance with customer satisfaction.
If any suspicious stance is found, our management shall visit our partner client, sales representative and explain the importance and value of customer satisfaction. In spite of our explanation, if they do not change their stance, we may refuse to conduct business with them.

basic principle for our employee (abstract)

We believe that employees are the most important resource for our company. We realize that we cannot grow and expand independently of its individual employees. Our leader’s important role is to create an environment that helps employee’s self-growth, in day by day operation.
Our employees will maintain high ethical standards and comply with laws and social norms; they will not commit a fraud, cheat or hurt others.
All of our employee comply with laws and regulations, not only in business activities but also their private life as a citizen of constitutional state. As a member of PB, we do not acts that disobey the laws and regulations.
We encourage all employees to think about how to improve of our business operations, and make them to give advice for management. Our employees keep in mind that it is important to make advice continuously, even if it’s not approved.

basic principle for our work environment

We believe that employees are the most important resource for our company. Our leader’s important role is to create an environment that helps employee’s self-growth, also every member of BP should make effort to act improving their ability.
Rewards and recognition within the organization are structured to recognize those people whose performance-based pay and promotion regardless of age, gender, nationality, or educational background. We recognize that personnel evaluation system based on performance-based, not rely on any other discriminatory factors.

basic principle for our customer complaints

We will continue our efforts with the "Customer First" principle; we believe that our prosperity does not exist without customer satisfaction.
We respond quickly and appropriately in a manner that places the highest priority on customer complain with sincerity.
We devote our sincere efforts to handling complaints even if it’s seems detailed matters.
We sincerely consider customers’ complain to improve our company. If we get same complaints more than twice, it must be our organizational problem. We must gratefully listen to and acknowledge our customers’ complain as a valuable contribution to solving our organizational problem, and our leaders should act quickly to solve them.
Responding a complaint is not the end of solving the problem. We investigate the cause of problem, and ensure that every employees share the information and we strive try to prevent recurrence.
We gratefully listen to and acknowledge our customers’ voices in daily, and we work to quickly react to their input. We are To provide a system for preventing a public space by detecting two pieces of detected information of extraordinary sound which is considered to be a dangerous signal which is not daily generated, and a direction of the extraordinary sound source, that is, a direction of sound source generated at a place where it is not daily generated. We have to take measures to solve the situation, provide a system which makes it impossible to occur. We recognize that our daily effort important elements to structure it. We understand that not taking action is neglecting their duties.

情報管理に関する心得および行動基本方針（抜粋）

compliance: We will comply with all laws and regulations and act based on noble business ethics when we handle confidential information, include customer information.
Clarification of handling standards: We recognize appropriate protection and use of confidential information is necessary to conduct our business. We make it clear when acquire, transmit, storage, backup and Under the rules and chief of administrator for confidential information, we manage confidential information in an appropriate manner.
Maintenance of organizational safety management system: We set up an organizational committee and chief of administrator to maintain and manage information security. Section leaders conduct roles and responsibilities regarding information security.
Strengthen physical safety management: We maintains physical access management of information assets by locking it away, supervising, restricting entry and exit access, monitor camera and other means to protect the information assets from the threat of leaks.
Enhancement of technical safety management: We conduct technical management involving the control of access to information systems, such as password, data encryption and the management of information systems development, operation and maintenance, along with preventative measures against leaks, alteration, loss, destruction, damage or the like.
Strengthen supervision of employees: We establish a framework to inspect and audit to ensure effectiveness of the system. We conduct audit twice a year, so it may prevent information leak incident or accident.
Collection, management, disclosure and suspension of use of personal information: We respect the rights of individuals concerning customer information. If a request for disclosure concerning the customer information is received from the individual concerned, we will respond to the request within a reasonable extent. In addition, if there are any changes in the customer information, we will respond promptly and if not we will explain the reason for that.

Our company's internal control action policy

Chapter 1 General rules

Objective: We will continue to ensure that laws and regulations are strictly observed, and social codes of conduct are honored. In order to put it into practice, we has established system to ensure Compliance of the Execution of Duties by Directors and Employees with Laws and Regulations and the Articles of Incorporation.
Definition: In our Basic Policy of Internal Control Systems, “Internal Control Systems” are described that process for assuring of an organization's objectives in operational effectiveness and efficiency, and compliance with laws, regulations and policies. Our Internal Control Systems measures business risk, check the accuracy and reliability of its accounting data, promote operational efficiency by following components, Controlling the environment, Risk assessment, Control activities, Information and communication, and Monitoring.
Content change: Basic Policy of Internal Control Systems will resolved at the Board of Directors meeting if change is necessary.

Chapter 2 Ensuring Compliance with Laws, Regulations of Social Ethics and Articles of Incorporation

Development of Compliance system

(Systems to Ensure Compliance of the Execution of Duties by Directors and Employees with Laws and Regulations and the Articles of Incorporation The Basic Policy is applicable to all company officers and employees.)

We has established Management Policy, Charter of Corporate Conduct & Action Policy, in accordance with Laws and Regulations and the Articles of Incorporation.
In its rules for the Board of Directors, In-house regulation for Money Lending Business Operation, we will continue to ensure that laws and regulations are strictly observed.
Establishing a department & assigning personnel that oversees compliance in charge of compliance to each department, streamlining the rules in relation to compliance and providing training on compliance awareness.
We establish and upgrade reporting routes for reporting any violations of laws, regulations or internal rules including suspicious one.
We establish Internal Audit Division, a unit reporting directly to the president, shall audit the suitability and appropriateness of business operation in accordance with auditor and Accounting Auditor.
We provide a statement of principle concerning the exclusion of antisocial forces in the Code of Ethics and the entire organization takes a collective response to such matters. We consider the prevention of damage from antisocial forces to be an important part of proper business activity. We shall never get involved with antisocial forces, conducting business with integrity operate with integrity work faithfully.

Systems to Preserve and Manage Information Pertaining to the Execution of Duties by Directors

We establish and maintain rules regarding the storage and management of documents, keep everyone informed about the responsibility and authority for document management. We shall put in place a syste

Chapter 3 Development of Risk Management System

Rules and Other Systems Regarding Risk Management

We shall stipulate risk management rules, to oversee group-wide risk management, and risk-prevention systems during normal operations.
Each section manager responsible for to identify and manage risks, and shall draw up action plan to prevent risk. They also promote and support the implementation of risk management of each business subsidiaries.
Each section shall monitor the progress of risk and measures to provide reasonable assurance that operation will carry out its business properly and efficiently.
Internal control division shall promote an understanding and implementation of risk management system more effectively and systematically.
The Internal Control Committee discusses and decides important issues concerning risk management, and conduct appropriate guidance and supervision for group-wide risk management.
The Management Conference adequately discusses important management issues, and they report to the Board of Directors meeting in particular important case.
When we recognize risk factors or important potential risk factors in relation to group-wide operation, each section leader must report matters promptly to the Internal Audit Division, in particular important case they report to the Board of Directors meeting.
To reinforce the risk management structure across the Group, Internal Audit division performs audits our group in cooperation with the internal audit sections of BP subsidiaries.

Chapter 4 Managing Business Efficiency

Ⅰ.Systems to Ensure the Efficient Execution of Duties by Directors

We ensure that the Board of Directors meeting is normally held on a periodical basis, and an extraordinary meeting is held when necessary.
We establishes the Management Conference and various committees so as to conduct decision making concerning the execution of duties delegated from the Board of Directors and prior deliberations on matters.
To ensure the efficient performance, and establish responsibility for, actions taken based on Board of Directors resolutions, responsible parties, their responsibilities, and implementation details shall be determined based on the Rules for General Organization, the Rules for Segregation of Duties.
To establish an assessment system linked to the performance results by drawing up an annual plan, budget control, etc., clarifying the objectives to be achieved by the Company.

Chapter 5 Ensuring Internal Control of Corporate Group

Ⅰ.Systems to Ensure the Propriety of Business Operations Conducted by the Corporate Group Consisting of the Company and Its Subsidiaries

In order to encourage effective Group management, support and guidance related to developing a proper and efficient business execution, compliance & risk management system shall be provided.
To support sound management at our subsidiaries, we dispatch or loan director and auditor to subsidiaries. In this way, we not only helps to ensure the businesses of the subsidiaries operate appropriately and efficiently, and but also communicates and shares information with subsidiaries. Internal Audit division performs audits in cooperation with the internal audit sections of subsidiaries, and gives necessary advice and suggestion for improvement with regard to the appropriateness and effectiveness of business operation.Corporate auditors will convene meetings as and when required with accounting auditor, and auditors of subsidiary companies to bolster collaboration and information exchange, and monitoring transactions between Group companies.
For the purpose of optimum benefit for the whole Group, we, as the management company of the Group, shall get involved with the subsidiaries’ management through periodic reporting from subsidiaries, getting approval by the Board of Directors particularly important matters as necessary, while respecting the autonomy of each subsidiary as an independent corporate entity.
We shall stipulate risk management rules; establish a Group-wide risk management structure. An Internal Control Committee is established within the Group Management Committee with the aim of support and guidance the internal control system. When we recognize significant facts that could have impact on the management of subsidiaries, we establish the Risk Management Committee, chaired by the President, in order to prevent enlargement of damage, by carry out in cooperation with external organizations.
We will undertake an overall review of its business structure, improvement & standardization of operational process, and promote operating efficiency and further streamlining of group-wide operations. Each Department shall cooperate with Group companies, and carry out implementation of the system.
We shall review and reassess periodically the adequacy of governance of subsidiary, by taking into account their corporate size, business lines, and organizational design, to establish more efficient sound management process.
Each subsidiary shall conduct business according to the division of duties and authority clarified in the company Rules of the Board of Directors, rules on authority, and any other related rules establish a code of employee conduct and apply it appropriately. We support to develop a system to allow efficient execution of business in accordance with regulations on operational authority.
Regarding compliance with the law, our managers themselves explain the importance of carrying on corporate activities in compliance with the law and corporate ethics to all members of staff, and by conducting training towards directors and general employees on a continuing basis, we are seeking to improve and increase directors’ and employees’ awareness of the law. The Internal Audit Office and the internal audit staff conduct internal audits subsidiaries concerning the establishment of managerial and operational systems and the legitimacy, rationality, and other aspects of business execution.Internal audit staff reports the result of audit to the board and the office, through those activities; we prevent violations of laws and regulations. If any violation found, we take appropriate action in a timely and manner.
We undergo periodic audits by the parent company, and collaborate with auditors and the internal audit division. We exchange information and opinions and sharing auditing reports.

Chapter 6 Ensuring the Effectiveness of Audits by the Board of Corporate Auditors

Systems to Ensure Effective Audits by Corporate Auditors,Installation of the audit the assistant and auditor auxiliary's independence

Upon the request of Corporate Auditor, we shall post exclusive employees assisting the duties of Auditors in accordance with the direction of such Auditors.

Appointment, termination, personnel transfer, evaluation, disciplinary action, and so forth, of or involving employees will require prior agreement of the Board of Corporate Auditors.

Corporate Auditors’ Staff may serve concurrently as Corporate Auditors of Associated Companies. Upon the request of Corporate Auditor, we shall exchange assisting employee duty without justifiable reason.

Upon the request of Corporate Auditor, The Directors, and employees shall cooperate to improve the auditing environment, we shall take the following actions.

We assure that each Corporate Auditor; Corporate Auditors’ Staff attend meetings of the Board of Directors and other important meetings.
We assure that Corporate Auditors’ Staff attend mutual opinion exchange meetings with President, Corporate officers and Accounting Auditors.

Systems for ensuring that directors and employees of the Company and directors etc. and employees of subsidiaries make reports to corporate auditors and other systems concerning reports to corporate auditors

The Directors and employees shall report to the corporate auditors about following matters.

Event of situations that may cause serious damage or disadvantage to the Company
Important information associated with the status of internal auditing
Violation of any law or regulation or the Articles of Incorporation of the Company

Directors, corporate auditors, and employees of subsidiaries promptly must report to the relevant subsidiary Directors, corporate auditors or the designated section when they find the above matters.A person who has received above information must report it to the Board of Corporate Auditors. We hall establish organizational controls to facilitate the systems necessary.

The Directors and employees, and Directors, corporate auditors, and employees of subsidiaries shall immediately reported to the Board of Corporate Auditors, about matters stipulated in laws and regulations and the Articles of Incorporation and the event Corporate Auditors request reports.

Anyone who reported above three sub section receives absolutely no unfair treatment by doing so.

Corporate Auditors have no obligations to report any third-party about the information concerning the reporting by The Directors and employees, and Directors, corporate auditors, and employees of subsidiaries.

Systems to Ensure Effective Audits by Corporate Auditors: Directors and employees of the Company shall report important corporate management and business administration matters, as well as the status and results of the execution of their duties, to Corporate Auditors so that the Corporate Auditors can carry out their duties effectively.; Corporate Auditors hold conferences with Representative Director, the Board of Directors, and Accounting Auditors, and exchange opinions with them, if requested.; Internal Auditing Division aims to collaborate with Corporate Auditors by providing timely and appropriate information necessary for them to execute their business duties, as well as by exchanging opinions and ideas.; We will be responsible for the necessary costs who are of conducting audit, and shall pay or reimburse the cost of audit to auditors unless if they can’t prove the cost of auditing activities.; We will appoint External Corporate Auditor who is outside professionals such as lawyers, certified public accountants, certified tax accountants, and other related experts. We shall enable the Corporate Auditors to collaborate with outside experts such as lawyers and certified public accountants, if any Corporate Auditor deems it necessary in executing their duties upon reasonable requeast.

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