Compliance

Basic Policy for Compliance

SLR and SRM are committed to ensuring compliance with relevant laws and regulations, preventing corruption and conflicts of interest, and ensuring appropriate information management, while taking into consideration human rights and diversity, through the establishment of the following policies and management structure.
SRM understands the importance of SLR's asset management business, where SRM manages the assets of SLR, as a business managing the funds of SLR's unitholders. To build an appropriate management structure, SRM established the Compliance Department in charge of compliance-related matters and appointed a Head of Compliance responsible for supervising compliance-related matters, thereby ensuring the effectiveness of the internal supervision of compliance in the other departments. In addition, SRM has established the Compliance & Risk Management Committee as a part of its establishment of a multilayered compliance system.

Compliance structure

Establishment and Implementation of a Compliance Manual

SRM has created a Compliance Manual to ensure compliance.
The Compliance Manual is revised as necessary in response to the enactment, revision, or abolishment of laws and regulations, and all executives and employees are notified of any revisions.

Compliance training

SRM implements thorough compliance through the appropriate operation of internal management systems designed to maintain the high ethical standards of its officers and employees, and ensure compliance with laws and regulations. To build a foundation for implementing these measures, SRM conducts training for its officers and employees to ensure that they have sufficient knowledge of compliance.

Internal Reporting System

When compliance issues arise, they are reported and handled through the established channels. In addition to the normal established channels, SRM has established a system that enables employees who notice issues to report them directly to a contact point when the established channels are difficult for some reason.

Responding to Compliance Violations

Article 12 of SRM's Compliance Regulations stipulate that if officers and employees, etc. become aware of any violation of laws or regulations or an action that is likely to violate laws or regulations at SRM, they shall report the violation or action immediately to the Head of Compliance or the Compliance Department.

Response to Anti-Social Forces

SRM has established regulations banning all relationships with anti-social forces. The regulations stipulate that the Compliance Department shall supervise the establishment of a system that prohibits all relationships with anti-social forces and deals with anti-social forces at SRM and that the Head of Compliance has supervisory responsibility over this. The regulations also stipulate that SRM shall provide internal training to officers and employees on guidelines for handling anti-social forces and the management of information about anti-social forces to increase their awareness.

In addition, SRM has declared a basic policy on anti-social forces to prohibit all relationships with anti-social forces, based on which it strives to develop a system that prohibits all such relationships. It has established regulations and standards for the verification of the customer's identity at the time of transactions and the reporting of suspicious transactions, to set standards for the verification of customers' identities at the time of transactions, the preservation of transaction records, and the reporting of suspicious transactions under the Guidelines for Anti-Money Laundering and Combating the Financing of Terrorism, the Act on Prevention of Transfer of Criminal Proceeds (the "Act"), the Order for Enforcement of the Act, and the Ordinance for Enforcement of the Act.

Prevention of corruption and bribery

Anti-corruption

As a member of the Sumitomo Corporation Group, SRM is engaged in initiatives to prevent bribery when entertaining business partners or giving gifts.
Specifically, in the Compliance Manual, we have established rules for preventing bribery. We have also established detailed rules regarding expenses for entertainment and decision-making authority, and detailed rules for handling of receiving gifts and invitations, which specify specific details.

Prohibition of political contributions

As a member of the Sumitomo Corporation Group, we are engaged in initiatives to prevent illegal political contributions.
Specifically, in the Compliance Manual, we have established rules prohibiting illegal political contributions.