The Purpose of Compliance

Shinsei Servicing Company (Shinsei Servicer) has always been committed to prioritizing efforts to comply with all laws and regulations concerning its business activities, to abide by the norms and values of greater society in all respects and to maintain focus on the continuous improvement of compliance efforts. As a company affiliated with Shinsei Bank and as a servicer licensed to operate by the Minister of Justice, we strive, through our fair business practices rooted in a firm sense of ethics, to play a significant role in the financial health of the economy, the sound functioning of a vibrant and fair society and the overall well-being of the general public.

Thorough Compliance Strategy

Our compliance efforts have consistently received praise from leading rating agencies for our continued focus on expanding and streamlining our Compliance Program by organizing internal rules, guidelines and manuals as well as holding regular and comprehensive training programs for all staff to strengthen compliance awareness throughout the Company. At Shinsei Servicer, each division is regularly evaluated by another division to identify compliance risks, and our standing auditor performs a semiannual inspection of all divisions to check internal controls and proactively identify any risks. Shinsei Bank, renowned for its own compliance efforts and overall contributions to society, also performs an annual audit of Shinsei Servicer to assess the appropriateness of administrative and internal controls, analyze the effectiveness of the Compliance Program and identify any business risks. Shinsei Servicer’s Compliance Division and Compliance Officer, together with our Compliance Managers representing all other divisions, review and amend our Compliance Program on a monthly basis.

The Significance of Compliance

Shinsei Servicer defines compliance as the "obeying of laws and regulations and abiding by social norms." As a servicer licensed by the Minister of Justice to engage in servicing operations, Shinsei Servicer will maintain sound management and will actively work for the benefit of Japan's economy and society. Securing the confidence of society is a critical mission for the company, requiring our employees to pursue their work according to the highest standards of professional ethics.

In order to conduct our duties fairly, in compliance with laws and related regulations and in line with social norms, we have created our "Compliance Program," "Compliance Guidelines," "Code of Ethics," "Code of Conduct," "Compliance Manual" and various related regulations to establish a set of concrete ethical standards that guide our business decisions and serve as part of our efforts to formulate and strengthen our compliance posture.