SMFG  2011 53 Compliance at SMBC Strengthening the Compliance System Appointment of Compliance Officers Creation of the Compliance Committee Management of the Compliance System Development of Compliance Programs Preparation of a Compliance Manual To be in compliance with laws, regulations, and other social  standards is basically and generally required for all corporations.  Especially for banks, compliance-related issues are particularly  important as their public missions and corporate social respon- sibilities are considered critical in the financial markets. In accordance with the basic policies of SMFG, SMBC  requires its management and staff to have the highest values to  gain public trust, abide by relevant laws and regulations, uphold  high ethical standards, and act fairly and sincerely. Therefore,  SMBC considers that being fully in compliance is one of the  most critical issues for management to appropriately deal with  the issues related to the Banking Law, the Financial Instruments  and Exchange Act, compliance with other related ordinances,  and elimination of anti-social organizations. SMBC adopts a two-tiered structure as its basic compliance  system as follows. At the first level, each department and office  is individually responsible for making preliminary decisions to  ensure that its conduct is in compliance with laws and regula- tions. At the next level, the independent Internal Audit Unit con- ducts strict audits of such departments or offices. In order to maintain this two-tiered structure and ensure  its effective operation, the Compliance Unit, made up of the  General Affairs Department and the Legal Department, plans  and implements the kind of systems and improvements to be  in compliance, under the directions of the management. The  Compliance Unit also provides guidance for and monitors the  activities of all departments and branches, and assists such  departments and branches to make appropriate compliance- related decisions. SMBC commits to the following activities to ensure that  such compliance structure functions effectively. companies intensify further, responding to amendments to the  Act on Prevention of Transfer of Criminal Proceeds, further  strengthening measures to eliminate transactions associated  with anti-social organizations, and strengthening the overseas  compliance measures appropriate for the growing overseas  operation and further strengthened regulations of each country. In addition to appointing compliance officers to each branch  and department of the bank, the “Area Compliance Officers,”  who independently function from frontline departments, are  appointed for the Middle Market Banking Unit and Consumer  Banking Unit to direct and oversee compliance activities at the  branches and offices. The Compliance Committee, which consists of cross- departmental compliance members, chaired by the director  in charge of compliance, has been created in order to com- prehensively review and discuss compliance related issues.  To enhance fair and objective deliberations by the Compliance  Committee, outside members are also invited to participate in  such Compliance Committee meetings. SMBC has prepared its Compliance Manual by stating the  objectives, guidance and 60 compliance principles in order to  assist the management and staff to be fully in compliance. This  manual has been approved by the Board of Directors. The Board of Directors develops a specific annual plan for  compliance-related activities for each fiscal year, including  amendments to the rules and regulations and training, for the  objectives of the compliance system for SMBC and its con- solidated subsidiaries to function effectively. During the fiscal  year 2011, SMBC will continue to strengthen its compliance  measures in order to quickly adapt to any changes in the social  environment. Such measures include strengthening the moni- toring of marketing and sales of risk products, appropriately  managing conflicts of interest as the cooperation among Group  For the handling of any complaints from and conflicts with our  clients, SMBC has executed agreements, respectively, with the  Japanese Bankers Association, a designated dispute resolution  agency under the Banking Act, and the Trust Companies  Association of Japan, a Designated Dispute Resolution  Organization under the Trust Business Act and Act on Provision,  etc. of Trust Business by Financial Institutions. Japanese Bankers Association: Trust Companies Association of Japan: Contact information: Consultation office, Trust Companies  Association of Japan Telephone numbers: (Japan) 0120-817335 or 03-3241-7335 Business hours:   Monday through Friday (except public and bank holidays) 9:00 am to 5:15 pm Contact information: Consultation office, Japanese Bankers Association Telephone numbers: (Japan) 0570-017109 or 03-5252-3772 Business hours:   Monday through Friday (except public and bank holidays) 9:00 am to 5:00 pm