Basic Policy for Conflict of Interest Management

The Group will manage transactions that may cause conflicts of interest and carry out business appropriately as follows so that the interests of customers will not be unduly harmed with respect to transactions with them.

The Group shall establish an independent conflict of interest management department, assign a person to be responsible for conflict of interest management, and appropriately manage conflicts of interest.
The Group shall identify transactions with potential conflicts of interest in advance into the following types and manage them.
1. Transactions for which interests of the customer and the Group conflict or interests of the Group’s customer and another customer conflict
2. Transactions for which the customer and the Group compete or the Group’s customer and another customer compete
3. Transactions in which the Group improperly uses information gained from a customer
One of the following methods or a combination will be selected, depending on the nature of the conflict of interest, to appropriately manage conflicts of interest.
1. Manage the situation by separating division(s) with potential for conflicts of interest
2. Alter conditions for the transaction with the potential for conflicts of interest on one or both sides or change the method of the transaction
3. Suspend transactions with the potential for conflicts of interest
4. Disclose the potential for conflicts of interest to the customer
5. Monitor the party with which information will be shared
The following Group companies shall be subject to conflict of interest management:
1. The Higo Bank, Ltd.
2. The Kagoshima Bank, Ltd.
3. Kyushu FG Securities, Inc.
4. The Higin Lease Co., Ltd.
5. Higin Card Co., Ltd.
6. Kyushu Digital Solutions Co., Ltd.
7. Higin Capital Co., Ltd.
8. JR Kyushu FG Lease Co., Ltd.
9. The Kagoshima Lease Co., Ltd.
10. Kagoshima Card Co., Ltd.
11. The Kyushu Economic Research Institute
12. The Kagin Agency Co., Ltd.