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ANTI-MONEY LAUNDERING POLICY

Based on this Basic Policy, the Company shall endeavor to prevent money laundering and terrorist financing (hereinafter referred to as ‘ML/TF’).

1.Establishment of Anti-Money Laundering and Counter-Terrorist Financing Framework

The Company recognizes the importance of preventing money laundering and terrorist financing, complies with applicable laws, regulations and guidelines, and endeavors to establish an appropriate framework.

2.Management Involvement

The Company's management recognizes the prevention of money laundering and terrorist financing as a key issue within its management strategy and will proactively and actively address this issue.

3.Identification, Assessment and Mitigation of ML/TF Risks

The Company shall identify and assess the ML/TF risks it faces and, based on the results, implement appropriate measures to mitigate those risks.

4.Customer Management Policy

The Company shall implement customer due diligence procedures in accordance with relevant laws and regulations and conduct appropriate customer management to strive to exclude transactions with inappropriate customers, including anti-social forces.

5.Detection and Reporting of Suspicious Transactions

The Company shall appropriately monitor transactions and, upon detecting a suspicious transaction, promptly report it to the authorities.

6.Audit of Compliance Status and Continuous Improvement

The Company shall regularly verify and conduct internal audits of its anti-money laundering and counter-terrorist financing framework, striving for continuous improvement.

7.Training of Officers and Employees

The Company shall endeavor to deepen the knowledge and understanding of its officers and employees regarding anti-money laundering and counter-terrorist financing through continuous training.

June 2024
Axvircle Co., Ltd.
Representative Director and President
Yuto Kamijo