Anti–Money Laundering Policy

MCP Partners Co., Ltd.

We, MCP Partners Co., Ltd., hereby acknowledge an importance of preventing money laundering, terrorist financing, and financing of proliferation (hereinafter referred to as “ML/TF”) and shall make our best effort to prevent ourselves and our group companies (hereinafter referred to as “MCP Partners”), including our customers and our employees, from engaging and/ or providing assistance to engage in ML/TF in order to contribute to maintain a stability and assist a development of the sound global financial system.

(Policy)

• MCP Partners shall comply with any laws and regulations related to preventing ML/TF that apply.
• MCP Partners shall not accept any customers or transactions involved with ML/TF.
• MCP Partners shall establish an appropriate framework to prevent ML/TF and conduct the following measures:
  • Risk assessment of ML/TF
  • Customer Due Diligence such as KYC for preventing ML/TF
  • Suspicious activity reporting and implementing applicable measures such as Asset Freeze

(Management Framework)
In order to establish an appropriate framework to prevent ML/TF, MCP Partners shall implement the following measures:

• Establishment and development of the organizational structure, policies and procedures for preventing ML/TF
• Trainings to ensure all directors and employees understand the importance of preventing ML/TF and awareness of each role and responsibility in the framework
• Assessment of compliance status of the framework for preventing ML/TF and sustained improvement of framework, based on the results of the assessment