Organogram

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Information security basic policy.

In order to realize our management philosophy, we strive to safely provide products and services which meet the needs of our customers and establish a strong relationship of trust with them.
It is important to protect the information assets necessary for providing our products and services and the information assets entrusted to us by our customers from various information security threats.

1. We will respect and comply with our agreements with customers regarding information security and legal or regulatory requirements.

2. Our Company shall establish an information security manager and an information security committee for the operation of the ISMS, and establish the necessary organizational structure.

3. In order to keep the risk of all important information assets handled by us at an acceptable level, we will establish systematic procedures and evaluation criteria for risk assessment and take appropriate risk countermeasures based on the risk assessment.

4. Our company regularly conducts education for all employees to maintain and improve ISMS.

5. We will strive to prevent information security incidents. And in the unlikely situation where an incident does occur, we will promptly take corrective action and improve our security level.

October 30, 2018
Muroosystems Co., Ltd.
Representative Director and President Pan Zhongxin

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Response to anti-social forces.

In order to ensure the soundness and fairness of the market and to ensure the safety of our customers and employees, we have established a system to eliminate anti-social forces such as organized crime groups and those affiliated with organized crime groups. We will sever all relationships with these forces.

1. Our Company will not engage in any transactions with anti-social forces.

2. If it turns out that a person already doing business with our group is an anti-social force, we will promptly take appropriate measures to terminate the transaction.

3. Our Company will never provide funds to anti-social forces.

4. Our Company will not respond to any unreasonable demands from anti-social forces. In the event which an unreasonable demand by anti-social forces is recognized, we will take civil or criminal legal action.

5. As for the elimination of anti-social forces, we will always build close cooperative relationships with related external organizations such as the police, the Center for the Elimination of Criminal Organizations, and lawyers.

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Basic policy on money laundering.

Our Company has established the following basic policy regarding anti-money laundering measures, complies with applicable laws and regulations, and strives to develop an internal control system.

1. The Company positions money laundering countermeasures as an important management issue, and appoints the representative director as the person in charge of money laundering countermeasures, and works on money laundering countermeasures.

2. In accordance with the concept of risk-based approach, we will take appropriate measures such as identification, evaluation and reduction of risks such as money laundering. In addition, we will periodically investigate and analyze transactions with customers and review the measures.

3. In order to eliminate customers and transactions with the purpose of money laundering, etc., our Company will conduct timely and appropriate measures at each stage of the start, continuation, and termination of business relationships by confirming at the time of transactions, monitoring, and creating transaction records.

4. Our Company will appropriately handle «suspicious transactions» detected through reports from each department and the results of transaction monitoring, and will promptly notify the authorities. In addition, in order to share information with management, the Board of Directors will report on the reporting status of «suspicious transactions» and reporting reasons.

5. We regularly audit the status of anti-money laundering measures and strive to improve our internal control system based on the results.

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Joint use of merchant information.

Muroosystems Co., Ltd. jointly uses member store information based on Article 27, Paragraph 5, Item 3 of the Personal Information Protection Act as follows.

1. About the member store information exchange system.
The Japan Consumer Credit Association (hereinafter referred to as the “Association”) has been certified by the Minister of Economy, Trade and Industry pursuant to Article 35-18 of the Installment Sales Act.
The Association collects, organizes, and provides information necessary to protect the interests of users (credit users), etc., which is one of the authorization operations, at the Merchant Information Exchange Center (hereinafter referred to as the JDM Center).

2. Report and use of information collected from Member Stores, etc.
The member companies of the Member Store Information Exchange System (hereinafter referred to as “JDM members”) shall review member stores upon receipt of an application for a member store contract, investigate member stores after the conclusion of a member store contract, take measures against member stores, and continue transactions. For the purpose of reviewing the information specified in “3. (2) Details of information to be jointly used” will be collected and used, reported to the JDM Center, and jointly used by JDM members.

3. Shared use of merchant information.
(1) Purpose of shared use
In the member store information exchange system operated as a business of a certified installment sales association stipulated in the Installment Sales Act, acts by member stores which lack the protection of users, etc. (including acts that are difficult to use), information on member stores necessary to protect users, etc., appropriate management of credit card numbers, etc., and prevention of unauthorized use of credit card numbers (hereinafter referred to as “credit card The Company shall report to the JDM Center information related to Member Store conduct which hinders the proper management of credit card numbers”) and information related to Member Stores necessary for the proper management of credit card numbers, etc., and JDM by providing it to members and using it jointly. We aim to improve the accuracy of JDM member’s screening at the time of signing a contract with a member store or during the process, eliminate malicious member stores, promote appropriate management of credit card numbers and promote credit transactions. The purpose is to contribute to the sound development and consumer protection.

(2) Content of shared information
　① Facts and grounds for investigation necessary for handling complaints related to the affiliated store, etc. in the individual credit purchase intermediation transaction.
　② Facts and grounds for canceling the contract pertaining to the intermediation of individual credit purchases on the grounds which the user did not protect the user in relation to the intermediation of individual credit purchases.
　③ Facts and reasons for the investigation necessary for proper management of credit card numbers, etc. by the member store in the contract for handling credit card numbers, etc.
　④ The affiliated store recognizes that the measures for proper management of credit card numbers, etc. by the member store, etc. in the credit card number handling contract do not conform to the standards stipulated in the Installment Sales Act, or may not conform to the standards. Facts and reasons for the measures taken against the store (including cancellation of the contract for handling credit card numbers, etc.)
　⑤ Objective facts related to actions which cause unfair damage to JDM members, users, etc., related to acts which fall under the protection of users (including those that are suspected to fall under or cannot be determined whether they fall under).
　⑥ Information which users (not limited to those who have already signed a contract) have reported to JDM members and information which is determined to be an act that lacks protection for users (information suspected of such acts and Including information that makes it difficult to determine whether an act has taken place).
　⑦ Information on acts which interfere with the management, etc. of credit card numbers, etc. performed by member stores.
　⑧ Information collected by the JDM Center regarding facts published by administrative agencies and their contents (information published as violating or likely to violate the Act on Specified Commercial Transactions, etc.).
　⑨ Information on acts which lack the protection of other users, etc.
　⑩ The name, address, telephone number and date of birth of the member store related to each of the above items (in the case of a corporation, the name, address, telephone number, corporate number and name and date of birth of the representative). However, among the information in ⑥ above, the name and date of birth (in the case of a corporation, the name and date of birth of the representative) are excluded for information that makes it difficult to determine whether the act has been committed.

(3) Holding period
The information in (2) above will be retained for a period not exceeding 5 years from the date of registration (in the case of ③ and ⑦, the date of completion of the measures in ④ corresponding to the information or the date of registration of cancellation of the contract). Scope of joint users who jointly use member store information.

4. Scope of joint users who jointly use member store information.
Comprehensive credit purchase intermediaries, individual credit purchase intermediaries, credit card number handling contract business operators, and JDM centers who are members of the Association and JDM members.
* JDM members are listed on the association’s website.
https://www.j-credit.or.jp/

5. Inquiries regarding the system and procedures for disclosure.
For inquiries and disclosure procedures regarding the member store information exchange system, please refer to 6 below. Please contact the JDM Center.

6. Operations manager.
Japan Consumer Credit Association Merchant Information Exchange Center (JDM Center)
Address: Tokyo, Chuo-ku, Nihonbashi Koamicho 14-1, Sumisho Nihonbashi Koamicho Building
Representative Director: Tetsuo Matsui
Phone number: 03-5643-0011 (representative)