Aoyama Sogo Accounting Firm Co. Ltd.
an independent member firm of PrimeGlobal

Internal Management Structure for SPC Management Services Internal Management Structure for SPC Management Services

Internal Management
Structure for
SPC Management Services

Regarding our Internal Management Structure for Seal Management and Cash Management Services

We, at Aoyama Sogo Accounting Firm, take the responsibility in serving our clients and investment communities at large very seriously. Our internal management structure is designed to prevent fraud and error resulting from foreseen risks. In particular, our seal management and cash management services are performed based on strict approval procedures and access restrictions as prescribed in our firm policies and manuals.

1. Seal Management and Flow of Affixing Seals to Documents

We assume that in principle, we maintain custody of the corporate seals in providing SPC administration management and nominee directorship services. We assign a specific manager with the key to the seal storage unit, and only a limited number of managers are given seal management authority.
Our approval procedure and flow of affixing seals ensures that there is segregation of duty among accounting personnel, seal manager, and staff in-charge of affixing the seal. This ensures that accounting personnel cannot directly touch the seals.

2. Cash Management Services

We have an independent cash management group which fully separates the roles of accounting personnel and fund settlement in-charge. This ensures that mutual checks and balance are in place for a highly secure fund management structure. Our flow of affixing seals incorporates strict approval procedures, with multiple internal checks amongst accounting personnel, seal manager, and staff in-charge in completing settlement of funds.
Additionally, the bank passbook received by us is managed through a device that automatically records a log of opening and closing, as well as through limited access rights and periodic monitoring of accounts.

3. Information Security Management

We know that secure management of information of individuals, clients, and projects is of utmost importance, and in February 2006, we were the first in the industry in Japan to obtain the international certification for Information Security Management System (ISMS) [ISO/IEC27001: 2005].
While maintaining ISMS and complying with annual ISO audits, our management measures considers risks in various situations, and to further strengthen security, all employees are actively engaged through internal education and compliance.
For more details about our Information Security Measures and ISMS General Policy.

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