Mercuria Holdings Co., Ltd. and its group companies (hereinafter collectively referred to as the "Group") will work to prevent money laundering and financing of terrorism (hereinafter referred to as "money laundering, etc.") based on the following basic policy.

1. Basic Policy

The Group recognizes that the prevention of money laundering, etc. is an important issue for management, and will develop and operate an appropriate management system in order to comply with applicable laws and regulations.

2. Organizational System

The Group will appoint the director in charge of the Compliance Department as the anti-money laundering officer, and the Compliance Department, which is the department responsible for measures against money laundering, etc., will work together with the Business Planning Department, the Finance & Control Department, and the Group companies to implement measures against money laundering, etc.

3. Risk Assessment Associated with Money Laundering, etc.

The Group identifies and assesses risks related to money laundering, etc. inherent to the Group's operations based on a risk-based approach, and formulates mitigation measures in accordance with those risks.

4. KYC

The Group will develop an internal system to ensure that checks are carried out at the time of transactions in a timely and appropriate manner. We will also take measures to mitigate risks in transactions with customers according to factors such as customer attributes, investment product, transaction type, and country (region).

5. Report of Suspicious Transactions

The Group will develop an internal system to monitor suspicious transactions and to notify authorities in a timely and appropriate manner in the event that a suspicious transaction is detected.

6. Provision of Training, etc.

The Group will provide its officers and employees with guidance and training, etc. to deepen their knowledge of preventing money laundering, etc., and to make them fully aware of the importance of such prevention

7. Internal Audits

The Group will periodically conduct internal audits of its internal system for the prevention of money laundering, etc., and will strive to improve the internal system based on those audit results.