AML/CFT Policy

JCB Co., Ltd. and JCB International Co., Ltd. (collectively, the “Companies”) comply, in accordance with the provisions of JCB General Principles and JCB Code of Conduct, with laws and regulations relating to AML/CFT that apply to the Companies' businesses.

In order to comply with these laws and regulations relating to AML/CFT, the Companies have established internal rules applicable to all of the Companies' officers and employees, have established and implemented a risk-based AML/CFT program that includes the measures set out below under the initiative of the Companies' senior management, and periodically review it.

1. 1.

   Appointment of an AML compliance officer

2. 2.

   Identification and assessment of risks

3. 3.

   Implementation of risk mitigation measures, including the following:
   (1) Customer due diligence, including verification of customer information
   (2) Compliance with economic sanctions imposed by the United Nations or other organizations, and compliance with applicable laws and regulations
   (3) Transaction monitoring
   (4) Reporting of suspicious transactions

4. 4.

   Regular education and training for all officers and employees

5. 5.

   Assurance of compliance with laws and regulations relating to AML/CFT by an independent audit department