Basic Policy on Anti-Money Laundering etc.

Operation policy

In order to prevent money laundering, terrorist financing, and proliferation financing (hereinafter referred to as "Money Laundering, etc."), the LY Corporation Group shall establish and maintain an appropriate control framework for the prevention of Money Laundering, etc. and develop a system for sharing information within the LY Corporation Group.
In addition, the specified business operators, etc. within the LY Corporation Group (meaning specified business operators as defined in Article2, Paragraph 2 of Japan's Act on Prevention of Transfer of Criminal Proceeds or group companies that are legally required to establish an anti-money laundering etc. program abroad) shall comply with all applicable laws and regulations and guidelines issued by authorities in Japan and foreign countries related to Money Laundering, etc.

Building and maintaining an appropriate control system and developing a program for information sharing

The LY Corporation Group regards the prevention of Money Laundering, Etc. as one of the most important management issues, and the management team shall be deeply involved in the building and maintenance of an appropriate control system based on a risk based approach. In addition, the LY Corporation Group shall develop systems such as meeting bodies to regularly share information within the Group.

Measures undertaken by the specified business operators, etc.

Based on the risks identified and assessed by each company, the specified business operators, etc. of the LY Corporation Group shall thoroughly implement the following measures to prevent Money Laundering, Etc.

• Appropriate confirmation at the time of transactions including identity verification
• Appropriate customer management measures, including ongoing customer management
• Conduct appropriate and periodic filtering and transaction monitoring
• Prompt notification of questionable transactions when "suspicious transactions" are detected
• Preparation and storage of various records pertaining to Money Laundering, Etc.

Training of officers and employees

In order to prevent Money Laundering, Etc., the LY Corporation Group shall enhance the expertise and awareness of its officers and employees by conducting regular training programs on the subject.

Verification of compliance

The LY Corporation Group shall monitor the status of compliance with laws and regulations related to the prevention of Money Laundering, Etc., and the effectiveness of the measures taken, and strive to continuously improve the system based on the results of such monitoring.

Unless otherwise specified, English-language documents are prepared solely for the convenience of non-Japanese speakers. If there is any inconsistency between the English-language documents and the Japanese-language documents, the Japanese-language documents will prevail.