Fundamental Policies Regarding Preventions of Money Laundering and Funds for Terrorist Organizations

CieloEX Limited (hereinafter referred to as "our company") reiterates it's determination to prevent money laundering and the financing of terrorism (hereinafter referred to as "money laundering, etc.").

In addition, our company firmly recognizes the importance of countermeasures to prevent money laundering, etc., and will comply with applicable laws to carry out business by establishing the following type of internal management systems.

1．Management policy

We have established the following basic policies as countermeasures against money laundering, etc. through our company. Based on the active, autonomous intervention of our administration team, we will make clear the roles of our staff and our entire organization concerning countermeasures against money laundering, etc.

(1) Our company will comply with all laws and regulations concerning money laundering, etc. measures.

(2) Our company's risk management team prioritizes countermeasures against money laundering, etc. as important risks.

(3) Our company will construct and maintain a firm risk management system against money laundering, etc.

(4) In order to identify and evaluate our own risks concerning money laundering, etc., as well as implement a reduction of such actions, our company will apply a risk, based approach detailing the counterplan for opposing the risk.

2．Structure of organization

Our company's highest decision-making body, the board of directors, is deeply involved in prioritizing the establishment of conditions to prevent money laundering, etc. as an essential problem and will outline basic policy.

3．Confirmation of transactions

Our company will make necessary adjustments to our in-house conditions so that we may take adequate measures at an appropriate time to deal with the confirmation of transactions.

4．Identification of suspicious transactions

Our company will make adjustments to in-house structure so as monitor areas such as transactions with customers and promptly take appropriate measures regarding suspicious transactions.

5．Customer management policy

Regarding the acceptance of customers, our company will take measures in accordance with methods such as the risk, based approach to rate the appropriate risk of customers.

In addition, we will consolidate an internal control environment to regularly verify and audit whether measures and standards are running efficiently by improving our the inner system necessary to take timely and appropriate measures.

6．Confirmation concerning measures such as freezing assets

Our company will make arrangements concerning measures against entities such as terrorists, such as freezing assets or others. 

In addition, we will thoroughly notify everyone regarding the prevention of money laundering, etc. so that the appropriate measure can be carried out in a timely manner.

7．Inspection of compliance

Our company will inspect the status of compliance and the effectiveness of countermeasures to prevent money laundering, etc. through an internal audit office and strive to continuously improve conditions based on inspection results. 

8．Preservation of records

Our company utilizes established policies and procedures concerning record keeping in compliance with applicable laws and regulations.

9．On-going training for officials and employees

The officers and employees of our company take training courses to acquire knowledge and improve awareness of the prevention of money laundering, etc.