Compliance System

As a trust bank engaged in the asset administration business, MTBJ aims to become a bank truly trusted and valued
by society by ensuring thorough compliance. To realize this philosophy, we develop the following measures and
systems.

Formulation of the Corporate Activity Ethics Standards.

We establish the Corporate Activity Ethics Standards to clarify our basic policy on compliance with laws and
regulations as well as specific standards of conduct. These Standards set forth ethics standards for realizing our
Management Creed, as well as specific standards of conduct.

Compliance activity

MTBJ formulates the Compliance Manual as a specific guide for practicing compliance based on the Corporate Activity Ethics Standards. This Manual is posted on the intranet that can be viewed by all officers and employees, and we ensure their understanding by conducting training as necessary in each division.
In addition, to achieve compliance, we formulate the Compliance Program for each fiscal year, based on which we implement our compliance activities and review the progress on a regular basis. Specifically, we regularly conduct compliance training, and each division regularly checks matters related to laws and regulations.
In light of anti-money laundering and economic sanctions compliance (AML), in order to establish an advanced AML structure that takes into consideration regulations under European and US laws, as well as Japanese laws, MTBJ enhanced its AML structure by including electronic messages for cash and securities settlement in international settlement screening, while further strengthening the know your customer control.

Organizational structure for practicing compliance

We have implemented the Compliance Committee chaired by the Director in charge of the Corporate Risk Management Division under the Management Conference to investigate and deliberate on important compliance-related matters.

In addition, we have the Corporate Risk Management Division as an oversight division for practicing company-wide compliance.
This division is responsible for planning and proposing various measures to implement effective compliance practices across the organization.
Furthermore, a compliance officer is appointed for each division to ensure compliance whithin each division.