Policy on Anti-Money Laundering and Countering the Financing of Terrorism

The Chugoku Bank Group (hereinafter, the “Bank Group”) recognizes that measures for anti-money
laundering, countering the financing of terrorism and counter proliferation financing (hereinafter,“AML/CFT/CPF”) is a priority task required not only domestically but also from the rest of the globalcommunity. Based on this recognition, the Bank Group shall take the initiative in establishing themanagement system in which it shall execute agile and effective responses to ever-changing
international situations and the risks facing the Bank Group, and set forth the following policy as abasis for execution of operations.

1. Management Policy
In order to execute agile and effective responses to changes in international situations, the Bank
Group shall take proactive steps to establish and maintain the management system based on theconcept of “risk-based approach,” in which it shall identify and assess its money laundering andthe financing of terrorism (hereinafter, “ML/FT”) risks in a timely and appropriate manner andtake mitigation measures that are proportionate to the risks.

2. Organizational Structure and OfficerThe Bank Group shall define AML/CFT/CPF as one of its critical management task and shallclarify the internal roles and responsibilities for that purpose. The Bank Group shall appoint theofficer in charge of the Corporate Administration Department or the duty executive officer ofChugin Financial Group, Inc. as the supervisory manager for AML/CFT/CPF. The Corporate
Administration Department shall act as the centralized function to ensure the execution of themeasures.

3. Measures for AML/CFT/CPF under Laws and Regulations
The Bank Group shall establish an internal system capable of carrying out timely and appropriate
measures for AML/CFT/CPF under laws and regulations, including, but not limited to, verification
at the time of transaction, retention of transaction records, confirmation of sanctions including
freezing of assets, and notification of suspicious transactions.

4. Administration of Customer Information and Policy for Handling Customers
The Bank Group shall establish an internal system for making appropriate investigations about thebasic information of customers in the course of the transactions with them and for carrying out
measures that are proportionate to their attributes. Furthermore, the Bank Group shall determineand carry out required risk mitigation measures by way of making periodic investigations andanalyses on the history of transactions with customers.

5. Transaction Monitoring and Screening
The Bank Group shall determine and carry out required risk mitigation measures by way ofinvestigating and analyzing the status of transactions by the use of reports submitted by its
branches or detection made by its computer systems for any unusual transactions or transactions
subject to sanctions.

6. Management of Correspondent Banks
The Bank Group shall endeavor to collect sufficient information about its correspondent banks,
conduct an appropriate assessment on them, and carry out appropriate measures that areproportionate to the risks involved. No relationship shall be established or maintained with any
shell banks without a physical presence or operations.

7. Development Training of Directors and Employees
The Bank Group shall continually conduct training or other programs for all of its Directors andemployees to deepen their understanding and raise their awareness of AML/CFT/CPF, in an effort
to develop and retain human resources having expertise and fitness for the given roles.

8. Verification of Status of Compliance
The Bank Group shall inspect the status of compliance with regard to AML/CFT/CPF, and basedon the results of such inspections, shall continually make efforts to improve its risk management
system against ML/FT.