AML/CFT policyBasic Policy on Measures against Money Laundering and Terrorist Financing

SMART EXCHANGE Inc. and its group companies (hereinafter referred to as "our company") operate the SMART EXCHANGE business, which installs and operates foreign currency exchange machines in tourist destinations, accommodation facilities, transportation facilities, and other locations in order to improve convenience for foreign tourists visiting Japan and expand consumption in the local economy, with the business philosophy of "making Japan the world's number one tourist country."

As a company engaged in this business, we have established hereby a basic policy on measures against money laundering and terrorist financing (hereinafter referred to as "money laundering/terrorist financing"), and will work to prevent money laundering and terrorist financing.

1. We position the prevention of money laundering and terrorist financing as an important management issue, and under the leadership of our management team, we will proactively and actively address this issue.
2. In order to tackle the prevention of money laundering and terrorist financing, we will establish the necessary system and provide training to our officers and employees to deepen their knowledge and understanding, and strive to maintain that system.
3. We identify and assess the risks associated with money laundering and terrorist financing and take appropriate measures to mitigate those risks.
4. We will strive to eliminate the risk of contact with anti-social forces and violations of sanctions by conducting identity verification in accordance with the Act on Prevention of Transfer of Criminal Proceeds and other relevant laws and regulations.
5. In order to detect suspicious transactions in a timely manner, we conduct monitoring based on risk assessment and, if we detect any, we promptly report them to the supervisory authorities.
6. We will properly store records related to money laundering and terrorist financing in accordance with applicable laws and regulations.
7. We will conduct regular internal audits to check measures against money laundering and terrorist financing, and strive to verify their effectiveness and make continuous improvements.

Established March 29, 2024 Last revised April 18, 2025 SMART EXCHANGE Co., Ltd.
Representative Director Masato Nakano