Compliance
Rakuten Bank understands its public responsibility as a bank, and is aware of the paramount importance of sound management policy and maintaining society’s trust and reliance, while conducting business operations with a high ethical standard. Therefore, the Bank requires its executives and employees to perform their duties with the highest ethical standards, while abiding by relevant regulations and laws, in accordance with the Bank’s social responsibility.
Compliance Structure
| System | Role |
|---|---|
| Compliance Division establishment | Rakuten Bank established the Compliance Division under the Executive Officer in charge of compliance to oversee Bank-wide compliance. Recognizing that compliance is enhanced by the awareness and actions of all employees, the Compliance Division strives to spread awareness of compliance in daily operations by formulating and implementing the Compliance Program, which is a concrete practical plan for achieving a robust compliance, and conducting training. |
| Compliance Committee meetings | The Compliance Committee was established, which meets on a regular basis, to review business matters from a compliance perspective. |
| Compliance Program formulation | The Compliance Division identifies issues and formulates compliance programs at the beginning of each fiscal year as a specific, bank-wide implementation plan for realizing an effective compliance system, with each plan approved by the Board of Directors. The Compliance Program includes (1) a plan for the development of compliance-related rules and manuals, (2) a plan for the implementation of internal controls related to compliance, and (3) a plan for education and training. The Compliance Division monitors the progress of the program quarterly and reviews the program as necessary. |
| Compliance and legal reviews | Compliance and legal reviews are conducted for various business projects by the personnel in charge of compliance and/or the compliance officer of each department and the Legal Affairs Department. |
| Executive and employee education and awareness | The Bank has established various rules including a code of ethics, compliance regulations, and compliance manuals, and reviews them as necessary. In addition, we make efforts to educate all our employees by conducting training for executives and employees, as well as thematic training for specific groups of employees. |
Money Laundering, Terrorist Financing, Sanctions Violations, and Proliferation FinancingPrevention Initiatives
As money laundering, terrorist financing, sanctions violations, and proliferation financing and financial crimes are becoming more complex and sophisticated, we recognize that our products and services can be used for these criminal activities. Under these circumstances, we consider that measures to prevent money laundering, terrorist financing, sanctions violations, and proliferation financing and other financial crimes are one of the most important management issues, and we are taking effective measures.
Regarding risks related to such financial crimes, adopting a risk-based approach, we have formulated and updated a risk assessment report that indicates countermeasures according to risk assessments by segment, and have established a management system that can respond to changing situations.
Basic Approach and Status of Provisions for Eliminating Antisocial Forces
＜Basic Approach to Eliminating Antisocial Forces＞
Based on the Rakuten Bank belief that it is essential to take a resolute stance against and eliminate any association with antisocial forces in order to maintain public trust in financial institutions and ensure appropriate and sound business operations, the group has established internal rules stipulating the promotion of a system for handling antisocial forces as an important part of the Bank's business operations and specifying details regarding how to respond to antisocial forces. The group strives to ensure that all employees are fully aware of these rules and that appropriate systems are in place. In addition, the “Basic Policy for Responding to Antisocial Forces” is published on the Bank's website.
＜Provisions for Eliminating Antisocial Forces＞
The Bank formulates plans for promoting efforts to eliminate antisocial forces within the Compliance Program, which is a specific, Bank-wide practical plan for realizing an effective compliance framework. These plans are resolved by the Board of Directors at the beginning of each fiscal year, and plan progress is reported to the Board of Directors on a quarterly basis.
The Compliance Division is responsible for the development of a system to eliminate antisocial forces.
To ensure the Bank responds to antisocial forces in an integrated manner, the President & CEO designates a person in charge of responding to antisocial forces in accordance with internal rules. This person is tasked with responding to antisocial forces and educating persons in charge of responding to antisocial forces.
We have also formulated and implemented internal rules and regulations aimed at eliminating antisocial forces in accordance with business operations. In addition to conducting periodic compliance training and internal education, we provide explanations to new employees upon joining the Bank to ensure they are fully aware of the importance of compliance.
The Rakuten Bank collaborates with outside specialized organizations including the Tokubouren and Anti-Organized Crime Campaign Center of Tokyo, as well as law firms with expertise in dealing with antisocial forces. In the event that antisocial forces are discovered among existing business partners, the group requests that its lawyers take countermeasures and cooperate with the police to respond to the threat.
The contracts that the Rakuten Bank enters into and the terms and conditions that it presents to customers include a clause for the exclusion of antisocial forces, which states that the group may terminate the contract if it is found that a counterparty or customer is associated with an antisocial force.
Establishment of an Internal Reporting System
In accordance with the amended Whistleblower Protection Act, the Bank has established the Compliance Hotline (a contact point for internal whistleblowing) and provides external reporting contact points (law firms, parent company hotlines and external reporting functions) enabling employees to make reports directly, facilitating the early detection and response to legal or regulatory violations.