MARUI GROUP Policy for Preventing Money Laundering and Terrorism Financing
MARUI GROUP (the Company and its subsidiaries and affiliates) recognizes that it has animportant management responsibility to prevent money laundering and terrorism financing, as
described in legislation on preventing transference of money appropriated through illegal means,relevant government ordinances, and guidelines issued by the relevant authorities (referred tocollectively as “relevant legislation” hereinafter). The MARUI GROUP Policy for Preventing
Money Laundering and Terrorism Financing has been established based on an understanding of thisresponsibility and compliance thereof is practiced to fulfill this responsibility.
1. Management Systems
Group companies that are applicable as specified business operators based on relevant legislation(referred to as “specified Group companies” hereinafter) create and maintain appropriate
management systems by defining the roles and responsibilities of personnel and organizations
related to the prevention of money laundering and terrorism financing, in order to ensurecompliance with the relevant legislation applicable to their business. In addition, a Groupwide
management system has been established to facilitate close coordination and the sharing ofinformation among Group companies.
2. Measures by Management
Members of management of MARUI GROUP spearhead measures for preventing money
laundering and terrorism financing in accordance with relevant legislation while pursuing ongoing
improvements to the relevant management systems as an important part of management strategies.
3. Risk Management
In accordance with relevant legislation, specified Group companies identify, assess, and takeappropriate measures to mitigate the money laundering and terrorism financing risks faced given
their respective products and services.
4. Customer Due DiligenceSpecified Group companies perform due diligence activities to confirm the identities of customers
when conducting transactions in accordance with relevant legislation and maintain records oftransactions and confirmations for use in preventing money laundering and terrorism financing.
5. Notification of Suspicious Transactions
Specified Group companies submit notifications of suspicious transactions and take other steps toprevent money laundering and terrorism financing as required by relevant legislation andgovernment authorities.
6. Employee Training
Specified Group companies provide training on the prevention of money laundering and terrorism
financing to all officers and employees in accordance with their roles to bestow the knowledge andfoster the awareness necessary to ensure compliance with relevant legislation and to cultivate a
corporate culture that is in staunch opposition to money laundering and terrorism financing.
7. Internal Controls
MARUI GROUP performs regular internal audits to verify the status of the systems for preventing
money laundering and terrorism financing described in this policy. The results of these audits areused to guide further improvements to internal control systems.
Established in August 2024
Hiroshi Aoi
President and Representative Director
Representative Executive Officer, CEOMARUI GROUP CO., LTD.