Summary of Conflicts of Interest Policy

[1]. Basic Policy

[2]. Transactions to be Managed

1. Sony Financial Holdings has established a structure and take all necessary action to prevent customers' interests from being harmed by the transactions outlined below ("transactions to be managed").
1. Transactions that put the Sony Financial Holdings Group's interest first in circumstances where there is a conflict of interest between the Sony Financial Holdings Group and customers
2. Transactions that profit from customer information
3. Transactions that profit from competing interests between customers
4. Other transactions in which it is evident that the interests of customers may be harmed by Sony Financial Holdings Group companies
2. For the purposes of the Management Policy Concerning Conflicts of Interest, "customers" whose interest should be protected are customers of the following businesses that Sony Financial Holdings Group companies engage in.
1. Sony Life Insurance Co., Ltd.
   Life insurance business, business of registered financial institutions, and other businesses that can be conducted by Sony Life under relevant laws and regulations.
2. Sony Life Insurance (Philippines) Corporation
   Life insurance business and other business that can be conducted by Sony Life Insurance (Philippines) Corporation under relevant local laws and regulations.
3. Sony Assurance Inc.
   Non-life insurance business and other business that can be conducted by Sony Assurance under relevant laws and regulations.
4. Sony Bank Inc.
   Banking business (including bank agency business by banking agents), business of registered financial institutions, and other business that can be conducted by Sony Bank under relevant laws and regulations.
5. Sony Bank Securities Inc.
   Trading of financial instruments and other businesses that can be conducted by Sony Bank Securities under relevant laws and regulations.
6. AEGON Sony Life Insurance Co., Ltd.
   Life insurance business and other business that can be conducted by AEGON Sony Life under relevant laws and regulations.
7. SA Reinsurance Ltd.
   Reinsurance business and other business that can be conducted by SA Reinsurance under relevant local laws and regulations.

[3]. Structure for Management of Conflicts of Interest

1. Structure
   Sony Financial Holdings has established a structure to manage conflicts of interest in the Sony Financial Holdings Group by making the director who is head of the Corporate Control Department responsible for oversight of managing conflicts of interest, and the Corporate Control Department the business unit responsible for the managing conflicts of interest.
2. Action
   The director responsible for oversight of managing conflicts of interest shall order Sony Financial Holdings Group companies to take the actions outlined below when the director deems them necessary on the basis of reports from Sony Financial Holdings Group companies, customer complaints, or other sources:
1. Block the flow of information between divisions where a conflict of interest may arise
2. Suspend the transaction concerned, or change the terms and conditions or method of the transaction
3. Disclose the conflict of interest, or the potential for a conflict of interest, to customers
4. Take any other action deemed necessary by the business unit responsible for the managing conflicts of interest
3. Record-keeping
   The division responsible for managing conflicts of interest shall maintain records as outlined below and retain them for five years.
1. Records that specify transactions to be managed
2. Records associated with actions taken to appropriately protect customers

As of March 1, 2010