Karibu Ltd. (hereinafter referred to as "Our Company") recognizes the importance of measures against money laundering and terrorist financing (hereinafter referred to as "ML/TF"). To prevent the services provided by Our Company from being involved in financial crimes related to ML/TF, we hereby establish a basic policy on ML/TF prevention as follows and build an effective internal management system based on it.
Our Company positions ML/TF countermeasures as a critical management issue and establishes and operates an effective internal management system to carry out ML/TF prevention under the proactive involvement of management.
Our Company designates the Compliance Department as the primary department for ML/TF countermeasures. In addition, Our Company appoints a senior manager in charge of ML/TF countermeasures from among the directors or executive officers, and under the direction of the said manager, Our Company works on ML/TF prevention across the organization.
Our Company comprehensively and specifically examines the risks associated with the products and services provided, transaction patterns, countries and regions involved in transactions, customer attributes, etc., and identifies ML/TF risks. Furthermore, Our Company assesses the impact of the identified risks and takes appropriate measures to mitigate the risks based on the results.
Our Company conducts appropriate customer management by regularly investigating and analyzing customer information. Moreover, at the commencement of the business relationship with customers, Our Company strives to exclude inappropriate customers, including sanctioned parties and antisocial forces, by making judgments on the acceptability of customers.
Our Company conducts transaction monitoring to ensure the effectiveness of ML/TF risk mitigation measures. If, as a result, "suspicious transactions" such as unusual transactions or sanctioned transactions are detected, Our Company appropriately deals with them and promptly reports them to the financial authorities.
Our Company's internal audit department audits the status of ML/TF countermeasures within Our Company in a timely and appropriate manner. Based on the results, Our Company verifies the effectiveness of ML/TF countermeasures and works on continuous improvement.
Our Company's officers and employees attend appropriate and continuous training on ML/TF countermeasures and strive to maintain and enhance the necessary knowledge and expertise.
Our Company hereby establishes and declares the following basic policy to prevent damage by antisocial forces, which are groups or individuals that pursue economic benefits by employing violence, force, and fraudulent methods.
1. Our Company will respond to antisocial forces as an entire organization and ensure the safety of employees who deal with antisocial forces.
2. Our Company will build close cooperative relationships with the police, lawyers, and external specialized agencies on a regular basis.
3. Our Company will sever all relationships, including business relationships, with antisocial forces.
4. Our Company will reject any unreasonable demands from antisocial forces and take resolute legal action.
5. Our Company will never engage in any backdoor deals or provide funds to antisocial forces.