Basic Policy on Anti-Money Laundering and Combating Financing of Terrorism

Sumisho Realty Management Co., Ltd. (hereinafter referred to as “SRM”) positions anti-money laundering and combating financing of terrorism (hereinafter referred to as “AML/CFT”) as one of the most important management issues, and will work on the prevention of ML/FT in accordance with the basic policy set out below.

  1. Development of ML/FT prevention management system
    SRM shall develop a management system to prevent its products and services provided to customers from being used for ML/FT.
  2. Management involvement
    SRM shall position AML/CFT measures as one of the most important management issues, and, under the leadership of management, develop an effective internal management system.
  3. Identification, assessment, and mitigation of risks associated with ML/FT
    Under a risk-based approach, SRM shall verify risks associated with products and services provided, types of transaction, countries/territories involved in transactions, customer attributes, and the like to identify and assess ML/FT risks and take appropriate measures to mitigate them based on the results.
  4. Customer acceptance policy
    SRM shall conduct the verification and risk assessment of customers, etc. at the time of transaction in accordance with applicable laws and regulations and strive to eliminate business relationships with inappropriate customers, including sanctioned persons and antisocial forces, by making decisions on whether to accept customers and conducting appropriate customer management. In the event that a customer does not respond to the verification at the time of transaction, or if the risk assessment of the customer based on the verification at the time of transaction indicates that the risk of ML/FT through transactions with the customer is not low even if appropriate risk mitigation measures are taken, SRM shall decline transactions with the customer.
  5. Monitoring and notifying suspicious transactions
    SRM shall conduct appropriate monitoring to detect suspicious transactions. If a suspicious transaction is detected, SRM shall notify promptly the relevant authorities thereof.
  6. Retention of documents, records, etc.
    SRM shall retain AML/CFT-related documents, records, and the like in an adequate manner as per the relevant laws and regulations.
  7. Audit and continuous improvement
    SRM shall conduct internal audits regarding the system for AML/CFT measures on a regular basis and strive for its continuous improvement.
  8. Education of officers and employees
    Through training, SRM shall endeavor to deepen knowledge and understanding of AML/CFT measures among its officers and employees.

Supplementary Provisions

(Responsible department and establishment, revision, and abolishment)
1. The establishment, revision, and abolishment of this policy shall be under the responsibility of the Compliance Department, and shall be made with the approval of Representative Director.

(Establishment)
2. This policy shall be established on July 1, 2024.