NIRAKU GC HOLDINGS INC.*
株式会社ニラク ▪ ジーシー ▪ ホールディングス(the “Company”)

ANTI-MONEY LAUNDERING POLICY

16 March 2015

* for identification purpose onlyAnti-Money Laundering Governance
1.

The Company’s board of directors (“Board of Directors”) is responsible for (among others)
overseeing the overall management of compliance risks, including the review and approval ofanti-money laundering (“AML”) measures as well as remediation of any issues that arise.

2.

The Company’s audit committee is responsible for (among others) reviewing any internal control
issues highlighted by the internal audit department and reporting such findings to the Board ofDirectors on a regular basis to highlight any deficiencies in the AML measures and internalcontrol systems.

3.

The Company’s senior management is responsible for ensuring that there is a robust AML
framework in place that is commensurate with any risks present in the pachinko industry.
Furthermore, they also ensure that such a framework is operating effectively to facilitate theidentification and mitigation of money laundering risks.

4.

The Company’s risk management committee is responsible for, among others, identifying,assessing and mitigating the risks faced by the Company’s business, which include thosepertaining to money laundering and compliance with the Three Party System. The risk
management committee periodically reviews these risks and the results of the internal audit
department’s testing and report their findings to the audit committee.

5.

The Company’s internal audit department is required to ensure adequate supervision on key
aspects relating to the prevention and detection of money laundering with respect to theCompany’s operations. This includes: (1) an inspection of each pachinko hall at least once every
two months; (2) periodic reviews of the Company’s compliance framework and effectiveness ofthe Company’s AML measures; (3) verification and testing of the Company’s compliance withAML measures; and (4) reporting any findings to the Company’s audit committee on a monthly
basis.

AML Operational Controls
6.

The Company implements the following controls to help detect and mitigate money launderingrisks in the pachinko halls:
appropriate due diligence procedures are conducted (including but not limited tobackground checks with respect to criminal records, employment history and financialinformation) and documented on the Company’s directors, as well as senior management,
and area and hall managers of the Company’s pachinko halls to among other things, identify
and avoid connections to anti-social forces and ensure high standards of integrity. Suchprocedures include screening of individuals against external search engines such as SP
Networks Co., Ltd* (株式會社エス▪ピー▪ネットワーク) to identify high risk individuals.
In addition, annual background checks are conducted on the Company’s G-prize
wholesalers and the G-prize buyers engaged by them, including their directors andshareholders, in order to identify and avoid any connections with anti-social forces. Suchprocedures include screening of individuals against external search engines such as SPNetworks Co., Ltd* (株式會社エス▪ピー▪ネットワーク) to identify high risk individuals;

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written representations are obtained on a periodic basis from the G-prize wholesalersconfirming (among others): (i) their independence from the Company; (ii) their
independence from the G-prize buyers with whom they conduct business; (iii) they and theirrepresentatives, statutory auditors, executive officer, shareholders and directors and also
the G-prize buyers with which they conduct business with do not have any connections with
anti-social forces, or are, or will be involved in any actions or activities using, or jointly
associate with any anti-social force; (iv) a complete and accurate list of all G-prize buyers
engaged by them who have G-prize buying shops near the Company’s halls, and theshareholder(s) or (ultimate owner(s)) of such G-prize buyers; (v) they undertake to conduct
their own regular background checks against any G-prize buyers engaged by them in orderto monitor any potential independence issues between them, and if there are any suchissues, to inform the Company and resolve them immediately to ensure compliance with the“Three Party System”; and (vi) they undertake to report to the Company in a timely manner
any change in their shareholding structure and composition of their board of directors, orif they become aware of any change in the same of the G-prize buyers engaged by them orother matters that may affect their own or such G-prize buyers’ independence within the“Three Party System”;

written representations are obtained on a periodic basis from G-prize buyers confirming(among others): (i) their independence from the Company; (ii) their independence from theG-prize wholesalers engaged by the Company; (iii) they and their representatives, directors,statutory auditors, executive officers or shareholders do not have any connections with
anti-social forces, or are, or will be involved in any actions or activities using, or jointly
associate with, any anti-social force; (iv) they are not aware of any of the Company’s Gprize wholesalers having connections with anti-social forces, or are, or will be involved inany actions or activities using, or jointly associate with, any anti-social forces; (v) they
have undertaken to the G-prize wholesaler that engaged them that they shall report to such
G-prize wholesaler in a timely manner any change in their shareholding structure or boardof directors or any other matters that may affect their independence within the “Three PartySystem”; and (vi) G-prizes are only paid for using cash and not any other form of paymentsuch as bank remittance or cheques;

external reputable corporate data research agencies are engaged to provide enhanced due
diligence information for any potentially suspicious customers or those customers withwhom there is an intention to conduct transactions exceeding a predefined transaction
threshold of ¥500,000;

periodic transfer of area managers and pachinko hall managers are conducted in order toprevent development of illicit relationships, such as those involving bribery. The
Company’s personnel development department shall have control over personnel matters;the Company reinforces monitoring of suspicious activities of customers and periodicevaluation. Efforts shall be made to ensure the early detection and reporting of persons whointend to gain profit illicitly by conducting thorough checks on suspicious activities;

there is to be continuous monitoring of the automated systems in place in the Company’s
pachinko halls, including but not limited to the Company’s prize management system,
information technology system and hall computers, as well as analysis of financial andoperating data, to monitor and detect unusual fluctuations that may indicate suspicious
activity;— 2 —there is appropriate guidance in place to ensure the timeliness, appropriateness and qualityof both internal reporting to the Company’s headquarters and external disclosure to therelevant authorities in Japan;

in the event where suspicious activities are discovered upon conducting an exhaustive
check of suspicious activities relating to anti-social forces and money laundering, theCompany’s staff in charge of compliance will be promptly alerted, in accordance with theemergency response flow. The Company’s staff in charge of compliance shall share suchinformation with the sales department and the responsible Director, and implement
appropriate responses when there is suspicion of money laundering;early detection of and response to abnormal values in the Company’s systems is alsoconducted. In particular, any act of exchanging pachinko balls or pachislot tokens for prizes
without playing shall be investigated. The Company’s hall staff will perform regularmonitoring of customers during operation hours to identify (among others) customers
exchanging prizes without playing. Further, at the end of each day, the Company’s hallmanagers will compare the ratio of the number of balls played to the number of balls rented
at the pachinko hall, with historical figures. If abnormal values are detected, the hallmanager will instruct hall staff to review surveillance camera footage of the day to identify
any customers who exchanged prizes without playing. Hall staff will also pay special
attention to customers on the next day to identify such suspicious activity. If the person
engaged in such activity does not cease the relevant activity after being asked to do so, suchact shall be immediately reported to the police. The Company may request such person toimmediate leave the premises and refuse the exchange of rent balls earned without playing;data checks are also performed on sales per machine and other business data every twohours during business hours to discover any renting of balls or tokens for purposes otherthan entertainment;moreover, at the end of each day, each hall must aggregate the number of pachinko balls
and pachislot tokens rent to customers, used in play, collected or exchanged with prizes andcheck for any abnormalities. Any ball which was not played but exchanged into prizes will
also be detected and the hall operation staff will need to report such instances to theCompany’s headquarters. This aggregation serves as an aid in detecting abnormal payout
status of prizes;

employee education for the prevention of money laundering shall be conducted incompliance with the Company’s management manual, and education on anti-money
laundering guidelines and other supplementary and updated information shall be conveyed
through various training programs. This will help ensure that there is sufficient awarenessfrom the Company’s staff of money laundering activities and risks;

the Company records customer information in relation to, and report to the Company’s
headquarters instances of, all transactions in which pachinko balls or pachislot tokens
totaling ¥500,000 or more are exchanged for prizes (per transaction). When a customer
seeks to redeem more than 100 G-prizes of large denomination, the Company’s hallmanagers or staff of a higher rank will (i) request for identification document; (ii) record
the name and address of the relevant customers and the circumstances of the redeem
request; and (iii) if there is any suspicious matter, track the relevant customer throughhis/her play history and the surveillance camera footage of the relevant customer;

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mechanical limitations, under which pachinko ball and pachislot token dispensers are only
able to release a maximum of approximately 750 pachinko balls or 600 pachislot tokens per
minute;specifications of the pachinko machines as regulated by the Amusement Business Law, theEnforcement Ordinance and the enforcement regulations prescribed under the Amusement
Business Law, which limit the possible payouts to (among others): (1) for pachinko
machines, it cannot release more than twice, or keep more than half, the number ofpachinko balls played in a ten-hour period; and (2) for pachislot machines, its payouts must
be between 0.55 to 1.2 times the number of tokens played over 17,500 continuous plays.

the Board of Directors is required to report any actual or potential money laundering
activity that has come into their attention through any internal communication channels orreporting mechanism described in this section to the relevant authorities in Japan.

In particular, as a result of the machine limitations set out above (some of which are required underJapan laws and regulations), money laundering through pachinko operations is difficult, especially asa lengthy period of time would be required to convert sizable sums of money into balls or tokens, andunusual activity in connection with play or failure to play will be observed and reported by theCompany’s staff.
7.

In addition, to ensure the independence of the Company’s pachinko halls from each of theCompany’s G-prize wholesalers and G-prize buyers engaged by them:

the Company regularly obtains from each of the Company’s G-prize wholesalers a list of
the shareholders (or ultimate owners) and directors of both themselves and the G-prize
buyers engaged by them;

the Company will annually obtain commercial registers of all the Company’s G-prize
wholesalers and the G-prize buyers engaged by them (provided that they are legal corporateentities) to review the composition of their board of directors;

the Company will engage independent third parties to perform annual searches on theshareholding structure and list of directors (if available) for all of the Company’s G-prize
wholesalers and G-prize buyers engaged by them;the Company requires the Directors, senior management and shareholders to confirm thatthey are independent of the Company’s G-prize wholesalers and such G-prize buyers (basedon the criteria set out above), and to notify the Company immediately if they become awareof any potential independence issues;

the Company will provide training on the “Three Party System” to its employees on aregular basis to ensure that they do not engage with G-prize wholesalers or G-prize buyers
engaged by them, and to prevent them from unknowingly establishing a relationship withthem;

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the Company requires that none of its management, Directors or staff are engaged in theG-prize buying business; and

as the Company’s pachinko operations are monitored by the Prefectural Public Safety
Commission* (都道府県公安委員會) in each relevant prefecture, in order to prevent any
conflicts of interest that might otherwise arise and for improved corporate governance,none of the Company’s Directors or senior management has been, or is, a police officer inJapan and the Company requires them to confirm so to the Company.

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