NIUM Japan’s AML/CFT and Countering Anti-Social Forces Principle

The board members of NIUM Japan hold ultimate responsibility in AML/CFT. The board members of NIUM Japan are aware that ML/TF is one of the most crucial risk elements in the business and they are responsible to lead establishment and maintenance of robust internal control.

NIUM is committed to have an effective “three-line defense model” for AML and CFT which sets three tiers of protection against the various risks posed.NIUM Japan adopts these 3 principles for countering Anti-Social Forces:

1. We recognise Anti-Social Forces as a threat to public order and social security, so that we as a whole organisation confront Anti-Social Forces and do not maintain relationships with, and terminate any existing relationship with, Anti-Social Forces with dignity.

2. We are determined not to accept unjust demands from Anti-Social Forces, we take necessary actions including legal actions for both civil and criminal procedure. And we do not facilitate any unjustified treatment of Anti-Social Forces including back room dealing, exceptional benefits or donation of funds.

3. We cooperate with external professionals, including but not limited to police agencies, Tokyo Center for Removal of Criminal Organizations and legal counsel when termination of a relationship, rejection of an unjust demand or any other contact with Anti- Social Forces arise.