Anti-Money Laundering Policy

The Group will establish an integrated internal control system based on the following policy regarding the prevention of money laundering, countermeasures against terrorist financing, and prevention of proliferation financing (hereinafter referred to as "anti-money laundering"), and in compliance with the Foreign Exchange and Foreign Trade Act, Act on Prevention of Transfer of Criminal Proceeds, and related ministerial ordinances and regulations (hereinafter referred to as "Foreign Exchange Acts and Ordinances, etc.").

The Group designates the Chief Compliance Officer of the Company as the person in overall charge of anti-money laundering, and the Risk Management Department of subsidiaries as the department to manage operations for anti-money laundering, and for compliance with the Foreign Exchange Acts and Ordinances, etc.

When verifying the identity of the customer, the Group will take appropriate measures in accordance with a risk-based approach, such as implementing measures in line with the attributes of the customer, such as official status.
In addition, we will record the results of periodic investigations and analyses of customer transactions and use these records to review our response measures.

The Group will collect and properly evaluate information of correspondents, and take appropriate countermeasures depending on risks of correspondents, as necessary. Furthermore, the Group will sever any relationship with any fictitious Group that does not conduct business in fact (so-called "shell bank").

The Group will provide ongoing training to its employees to ensure proper customer management, including verifying the identity of the customer and preparation of transaction records.

The Group will periodically conduct internal audits on the status of anti-money laundering, and compliance with Foreign Exchange Acts and Ordinances, etc., and based on the audit results, will strive to further improve its system.

The Group shall establish a system to appropriately deal with suspicious customers and transactions, etc., detected as a result of daily monitoring according to internal rules and well-developed systems depending on the business, and promptly report them to the authorities.

The Group will strive to reduce the risk of sanctions violations by ensuring that each subsidiary has a good understanding of the intent of Foreign Exchange Acts and Ordinances, etc., and by establishing a system to handle foreign exchange transactions in compliance with Foreign Exchange Acts and Ordinances, etc.

End