Anti-Money Laundering and Combating Financing of Terrorism Policy

1. Compliance with Laws and Regulations

The Group will comply with all of relevant laws and regulations concerning AML/CFT.

2. Management System

The Group will clarify the role and responsibility of managers or persons in charge of AML/CFT. We will ensure the consolidated management in cooperation with all of the related departments appropriately.

3. Risk-based Approach

To ensure preventing AML/CFT, the Group will identify and evaluate the risks faced timely and appropriately and we will take mitigation measures according to the magnitude of the risk. In line with the concept of our risk-based approach, we develop the management system for AML/CFT and operate appropriately.

4. Compliance with customer acceptance policy

The Group establishes customer acceptance policy to protect from money laundering, etc. Based on this policy, we will prevent transactions with customers at unacceptable level of risks.

5. Appropriate Business Procedures

The Group establishes the necessary business procedures for AML/CFT and carries out appropriately as follows;

• Measures for securing appropriate management of customer identification at the time of transactions, Confirmation of existence of deposit accounts subject to economic sanctions, Record concerning customer identification and transactions and its storage, Detection and reporting of suspicious transactions.

6. Correspondent banks

The Group will collect and evaluate properly information of correspondent banks, and take appropriate countermeasures as necessary. Furthermore, the Group will sever any relationship with any fictitious banks (so-called "shell bank") and other banks that allow them to use their accounts.

7. Training and Educating

The Group will provide ongoing training and educating for all of officers and employees to ensure AML/CFT and foster a corporate culture that stringently respond to them.

8. Internal Audit

In order to effectively function the risk management system including AML/CFT, the Group will conduct internal audits on the status of AML/CFT on a regular basis by the Internal Audit Department, and work to improve its systems based on the results of such audits.