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 at the workplace. 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 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. The Corporate Risk Management Division plans and proposes various measures for practicing
company-wide compliance. In addition, a compliance officer is appointed at each division for practicing compliance
at the division.

Compliance Helpline

We have a system in place for an employee to directly report to an internal or external reporting desk to find and
correct compliance issues as early as possible. Upon receiving a report, the Corporate Risk Management Division,
the division supervising compliance, takes action, such as clarifying facts, correcting problems, and developing
preventative measures.

Internal control