October 2021 All Out Life

All Out Life (hereinafter referred to as “our company”) recognizes the importance of countering money laundering and terrorist financing (hereinafter referred to as “money laundering, etc.”). In order to prevent people from being involved in financial crimes, we have established the following basic policy regarding the prevention of money laundering, etc., and have established an effective internal control system based on this policy.

1. Developing and operating a system to prevent money laundering, etc. The Company regards countermeasures against money laundering, etc. as an important management issue, and with the active involvement of management, develops and operates an effective internal control system to prevent money laundering, etc.
2. Organizational posture The Company’s Compliance Department will be the department in charge of measures against money laundering, etc. In addition, we will appoint a person with overall responsibility for anti-money laundering measures from among our directors or executive officers, and under the direction of this person, we will work to prevent money laundering across the organization.
3. Risk identification, assessment, and mitigation Based on a risk-based approach, we comprehensively and specifically examine the risks associated with the products and services we provide, transaction formats, countries and regions involved in transactions, customer attributes, etc., and identify risks such as money laundering. To do. We also evaluate the impact of identified risks and, based on the results, take appropriate measures to reduce risks.
4. Customer management policy Our company conducts appropriate customer management (customer due diligence) by regularly investigating and analyzing customer information, etc. Furthermore, at the beginning of a business relationship with a customer, we will strive to eliminate inappropriate business relationships with customers, including sanctioned persons and anti-social forces, by determining whether the customer is acceptable or not.
5. Reporting suspicious transactions The Company conducts transaction monitoring to ensure the effectiveness of measures to reduce risks such as money laundering. As a result, if we detect “suspicious transactions” such as abnormal transactions or transactions subject to sanctions, we will take appropriate action and promptly notify the relevant authorities.
6. Audit of initiative status and continuous improvement The Company’s internal audit department conducts timely and appropriate audits of the Company’s efforts to combat money laundering, etc. Based on the results, we will verify the effectiveness of our anti-money laundering measures and strive for continuous improvement.
7. Training for executives and employees Our officers and employees will appropriately and continuously receive training on countermeasures against money laundering, etc., and strive to maintain and improve the necessary knowledge and expertise.