Glow Co., Ltd

We, Glow Co., Ltd, hereby acknowledge an importance of preventing money laundering, terrorist financing, and financing of proliferation (hereinafter referred to as “ML/TF”) and shall make our best effort to prevent ourselves and our group companies (hereinafter referred to as “GLOW”), including our customers and our employees, from engaging and/ or providing assistance to engage in ML/TF in order to contribute to maintain a stability and assist a development of the sound global financial system.

 

Policy

GLOW shall comply with any laws and regulations related to preventing ML/TF that apply.

GLOW shall not accept any customers or transactions involved with ML/TF.

GLOW shall establish an appropriate framework to prevent ML/TF and conduct the following measures:

• Risk assessment of ML/TF
• Customer Due Diligence such as KYC for preventing ML/TF
• Suspicious activity reporting and implementing applicable measures such as Asset Freeze

 

Management Framework

In order to establish an appropriate framework to prevent ML/TF, GLOW shall implement the following measures:

• Establishment and development of the organizational structure, policies and procedures for preventing ML/TF
• Trainings to ensure all directors and employees understand the importance of preventing ML/TF and awareness of each role and responsibility in the framework
• Assessment of compliance status of the framework for preventing ML/TF and sustained improvement of framework, based on the results of the assessment