Basic Policy on Anti-Money Laundering and Anti-Terrorist Financing

Operation policy

In order to prevent money laundering and terrorist financing (hereinafter referred to as "Money Laundering, Etc."), Z Holdings Corporation and its subsidiaries and affiliates (hereinafter collectively referred to as the "Z Holdings Group") shall develop an appropriate internal control system for the prevention of Money Laundering, Etc. and develop a system for sharing information within the Z Holdings Group. In addition, in accordance with the laws and regulations of Japan and other countries and international requirements concerning Money Laundering, Etc., (e.g., Japan's Act on Prevention of Transfer of Criminal Proceeds and guidelines, etc., published by the supervisory authorities), the specified business operators within the Z Holdings Group shall develop an appropriate internal control system based on a risk-based approach that takes into consideration the business conditions of the specified business operators within the Group.

Framework of internal control system and information sharing system

The Z Holdings 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 development of a system for its prevention.　In addition, the Group shall establish and operate systems such as a meeting body to regularly share information with the specified business operators within the Group.

Measures undertaken by the specified business operators

Based on the identification and assessment of risks within the Z Holdings Group and each Group company, the 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 based on the results of the above
- Appropriate and periodic transaction filtering and transaction monitoring
- Prompt notification of questionable transactions when "suspicious transactions" are detected
- Preparation and storage of necessary records pertaining to the above

Training of officers and employees

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

Verification of compliance

The Z Holdings 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.