FGI - FinTech Global Incorporated

FGI Group Principles of Ethics and Conduct

FGI and its subsidiaries—collectively, “the FGI Group”—adhere to the following five principles, which clearly describe the conduct required of all executives and full-time and contract employees under the Group umbrella. With respect for human rights and concerted efforts to observe associated laws, international rules and the spirit of them, in Japan and abroad, the Group ensures that business activities are executed sincerely and appropriately.

Note that the Company maintains a separate set of compliance standards, which executives and employees of the Group are required to abide by, and endeavors to maintain a corporate atmosphere and corporate structure built upon the FGI Group Code of Conduct.

1. Build trust

Honesty in execution of duties based on high standard of ethics

In executing our assigned roles, we will be guided by high moral standards that ensure management transparency and business practices undertaken honesty and with integrity. At no time will facts be distorted or the truth be concealed through false reporting or any other such misconduct.

Adherence to duty of confidentiality and meticulous information control

Suitable internal rules have been established and measures implemented to prevent inappropriate disclosure and accidental leaks, ensuring that client information made known to members of the Group in the course of business is handled in strict confidence and that disclosure of information pertaining to the Group’s business activities is properly executed.

Proper accounting treatment and information disclosure

No one will engage in inaccurate accounting treatment or make entries into the Company’s books in such a way as to invite untruthfulness or misinterpretation. The disclosure of corporate information about the Group will be made in all sincerity, based on facts.

2. Assume client perspective

Sincere, sensible responses

When dealing with clients, we will be considerate, polite and sincere in our actions. We will assume a client’s perspective to better safeguard returns from their investments. In addition, entertainment and gift-giving will be kept within socially acceptable limits.

Adhere to rules of suitability and emphasize accountability

We will provide products and services we feel are appropriate, given clients’ needs and investment experience. The advantages, disadvantages, risks and other aspects of investment will be properly explained to clients to ensure that they fully understand the issues when they enter into transactions.

Confirm intentions

When closing contracts, we will ensure that clients have a firm understanding of the contents therein and that each contract is built around the investment objectives of each client.

3. Unwavering respect for laws

Respect for laws

As a general financial group, we will pursue business opportunities with honesty and integrity, adhering strictly to rules and laws in Japan and abroad. We will seek to uphold a high standard of ethics and create a corporate atmosphere that emphasizes respect for rules and laws. Efforts will be made to reinforce practices and instill a deeper awareness of legal and regulatory compliance within the Group.

No inappropriate transactions allowed

It is not our practice to solicit transactions through the use of dominant position to pressure clients into financial deals. We will not engage in methods that sacrifice client interests so that an individual company or companies under the Group umbrella may benefit.

Whether at home or abroad, we will respect anti-monopoly laws, fair competition laws and laws established to maintain fair transactions, and we most certainly will not engage in any sort of collusion or cartel activity.

We will not use information acquired in the course of business in any endeavor designed to achieve personal gain. In particular, we will not pursue stock trades based on undisclosed material facts that could impact the price of the Company’s shares or that of client companies. Should information pertaining to material facts come into our hands, it will be handled with the utmost care. Within the FGI Group, no company will act in any way that would compromise the position of other companies. Should client information not made public be handled or conveyed between Group companies, the utmost care will be taken to prevent prohibited actions and socially unacceptable application of such information.

Dealing with public institutions, handling political contributions and donations

Associated laws will be respected in dealing with officials, civil servants and public institutions and in handling political contributions and donations.

Acknowledging intellectual property

We will properly safeguard intellectual property rights (patent rights, trademarks, copyrights, etc.) originated within the Group and also acknowledge third-party intellectual property rights.

No mixing of private and public interests

We will strive to make value judgments from a fair and impartial perspective, free from any conflicts of interest. A clear division will be made between private and public pursuits, and corporate assets will not be diverted for private use.

4. Respect for human rights and the environment

Respect for human rights

In the fundamental spirit of respect for humanity, no one will be discriminated against due to race, nationality, beliefs, religion or gender nor will the human rights of anyone be violated.

Cultivating comfortable workplace environment

Executives and employees, as partners supporting each other on the job, will respect one another. Sexual harassment and bullying in the workplace (power harassment) will be recognized as actions that injure human dignity and efforts will be made to eliminate such behavior.

Coexisting with society

We will strive to deepen mutual understanding with communities and build bonds of trust to ensure a harmonious coexistence with society, and we will endeavor to operate as a business that contributes to society.

Environment-conscious perspective

We will respect environment-related agreements and legislation. We will also use resources and energy efficiently, endeavor to reduce the amount of waste from our offices and save energy, protect the global environment and preserve natural spaces.

5. Firm stand against “anti-social forces”

Firm stand against "anti-social forces"

With a resolute attitude, we will take the following steps to deal with groups or individuals such as crime syndicates and racketeers, known in Japan as “anti-social forces,” which pursue economic benefit through the use of violence, force and fraudulent means.

  1. (1)In the event FGI or a member of the Group is faced with an inappropriate request from anti-social forces, the issue will not be resolved through simple problem-solving techniques using money.
  2. (2)Antisocial forces may deviously enter into ordinary transactions. In providing services and pursuing deals, we will therefore carefully execute checks before and after any business transaction to prevent relationships from being established in the first place and to terminate any relationships that are later found to involve antisocial forces.

No money laundering

We are aware that funds handled through a financial institution have the potential to be used to finance criminal activities or terrorism. We will meticulously confirm the identity of individuals initiating transactions and any transaction suspected of having criminal intent will without execution be appropriately addressed. Money laundering will not be tolerated.

Supplementary Provisions

(Amendments to Principles of Ethics and Conduct)
Article 1
Revision or abolition of content in the Code of Conduct shall be made through procedures established under Rules for Rule Management.

(Date implemented)
Article 2
This Code of Conduct takes effect December 16, 2005.

July 1, 2007 Revised
February 24, 2012 Revised
April 20, 2012 Revised

Page Top