Basic Policy on Eliminating Anti-Social Forces, Preventing Money Laundering, and Countering the Financing of Terrorism

Rheos Capital Works Inc. is committed to the following basic policy in order to prevent involvement with any organized crime groups or other groups that threaten social order and security, which are commonly referred to as "anti-social forces" in Japan, and to respond resolutely to threats presented by such groups.

1. Organizational measures
   Recognizing the importance of eliminating transactions with anti-social forces, including preventing money laundering and the financing of terrorism, we will take appropriate measures across the organization that include the involvement of all employees, including executive managers.
2. Cooperation with external professional organizations
   We will work closely with external professional organizations such as the police, the National Center for Removal of Criminal Organizations, and law firms.
3. Barring all relationships and business transactions with anti-social forces
   We will not tolerate any relationships (including business transactions) with anti-social forces.
   When conducting transactions, we will use the list of anti-social forces maintained by the General Affairs Department as well as the list of economic sanctions and persons subject to economic sanctions published by the Ministry of Finance, along with certified copies of the register to block transactions with anti-social forces, those subject to economic sanctions, and shell companies.
   If any of our clients are identified as being affiliated with anti-social forces, an individual or entity subject to economic sanctions, or a shell company, we will quickly sever all business ties with them.
   We will also reject any unreasonable demands issued by anti-social forces.
4. Civil and criminal action in the event of an incident
   We will file both civil and criminal suits to deal with unreasonable demands issued by any anti-social forces.
5. Prohibition of under-the-table transactions and hush money
   We will never submit to attempts by anti-social forces to extort hush money or engage in under-the-table transactions in exchange for covering up fraudulent business activities or employee misconduct.
6. Ensuring the safety of employees
   We will ensure the safety of employees who must deal with anti-social forces in the course of their jobs.
7. Risk mitigation
   We will take appropriate measures in line with the concept of risk-based approaches (i.e., identifying and assessing risks in a timely and appropriate manner, and taking appropriate measures to reduce such risks).
8. Pre-transaction verification
   We will have a system in place to ensure that appropriate steps are taken to vet clients before engaging in a transaction.
9. Economic sanctions such as asset freezing
   We will have a system in place for freezing the assets of an entity or individual subject to economic sanctions.
10. Reporting suspicious transactions
    We will establish a system to promptly notify the authorities of suspicious transactions and clients.
11. Training for officers and employees
    We will provide employees, including executive officers, with ongoing guidance and training to help them gain knowledge and an understanding of the measures designed to stop anti-social forces, money laundering, and the financing of terrorism, as well provide them with information regarding the steps taken to be taken to ensure appropriate client management, including with respect to pre-transaction vetting and the monitoring of transactions.
12. Inspection of compliance status
    We will regularly conduct internal inspections to check the status of compliance with measures designed to stop anti-social forces, money laundering, and terrorist financing, and work to enhance compliance based on the results of those inspections.