Risk Management—Compliance
Measures and Elimination
of Antisocial Forces

Our Compliance MeasuresAoyama Sogo Accounting Firm (“we”, “us”, “our firm”) complies with laws and regulations and follows the compliance measures described below in conducting our business activities with integrity and ethics.

1. Compliance Structure

To ensure optimal compliance, our organization and reporting lines are structured as follows.

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2. Whistleblower Policy

An internal help desk is available for all employees for the purpose of early detection, response, and incident prevention of compliance issues.

3. Employee education

We provide employee education for the purpose of gaining greater understanding of compliance issues.

Elimination of Antisocial Forces

We have devised a “Response Policy for Antisocial Forces” for the purpose of blocking relationships with antisocial forces and preventing damages in the event that such forces seek contact with us. All employees are united in the elimination of antisocial forces. Our main initiatives are outlined below.

1. Our Basic Stance towards Antisocial Forces

We hold a resolute stance towards antisocial forces, block any relations with such forces, and firmly reject any unreasonable requests received. We will swiftly terminate engagement with any existing client who is found to be an antisocial force.

2. Collection and Management of Information on Antisocial Forces

In cooperation with police and other specialized external agencies, our compliance committee collects and manages information regarding antisocial forces, and implements a response manual to educate our firm members about potential contact from antisocial forces.

3. Employee Education

We provide periodic employee education for the purpose of blocking any relations with antisocial forces and preventing related damages.

4. Cooperation with External Agencies

We will request the cooperation of police, the National Center for Removal of Criminal Organizations, legal advisors and other such external agencies in preparing an organizational response.