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regulatory compliance

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when chailease holding went public in 2011, it voluntarily raised its regulatory compliance standards. just like financial institutions, it established special business units to develop regulatory compliance management practices. other major subsidiaries, including chailease finance co., ltd. and chailease international finance corporation, also developed regulatory compliance management practices. they regularly hold regulatory compliance training and awareness programs to ensure their operations and products comply with internal and external regulations. in addition, they conduct annual internal regulatory compliance inspections and report the results to the board of directors.

the company appointed a regulatory compliance director and created the legal department to manage the regulatory compliance system. this department is responsible for planning, implementation, management, and assessment. its main duties include clear and appropriate conveyance of compliance information, consultation, coordination and communication, verification that operation and management policies comply with current laws and regulations.

in 2018, chailease created the dedicated position of corporate governance officer. at the same time, the chailease holding legal department, secretarial office, and administrative department duties were adjusted. corporate governance employees in the secretarial office and administrative department, in matters of corporate governance, are under the jurisdiction of the legal department. the corporate governance officer oversees the legal department as it implements corporate governance. in addition to statutory corporate governance, the corporate governance officer also coordinates the company’s legal affairs. the results of self-inspection in 2019 are in compliance with the laws and regulations.

in response to revisions to the scope of taiwan’s money laundering control act, which added financial leasing activities, the company will undertake to implement all legal requirements and procedures required of financial leasing companies. chailease will do our utmost to coordinate with competent authorities. while fulfilling our corporate social responsibility, combating money laundering and terrorist financing, and minimizing costs, we will assist the taipei leasing association to work with the competent authorities and consultants to complete the questionnaire and create a template.

due to the addition of financial leasing activities to the scope of taiwan’s money laundering control act, chailease and our key subsidiaries have established the below policy to prevent money laundering and terrorist financing:

1. in order to fulfil its responsibilities as a global citizen by strengthening controls to prevent money laundering and terrorist financing, the taiwanese government, in accordance with the financial action task force’s 40 recommendations, drafted the counter-terrorism financing act that took effect on july 27, 2016 and the money laundering control act that was revised and passed on december 28 of the same year. for the first time, financial leasing operations came under the scope of the anti-money laundering law, which took effect on june 28, 2017. on june 25, 2018, the financial supervisory commission announced the regulations governing anti-money laundering of financial leasing enterprises.

2. taiwanese subsidiaries chailease finance co., ltd. (“chailease finance”) and fina finance & trading co., ltd. (“fina finance”) are both members of the taipei leasing association. in accordance with money laundering control act requirements, know your customer procedures must be implemented at the point of lease financing (excluding consumer goods finance leasing) and later transactions must be monitored. significant cash transactions or other red flags that may indicate money laundering or terrorist financing must be reported to the anti-money laundering division of the ministry of justice. as of the end of december 2019, the subsidiaries of the company, chailease finance and fina finance, had not reported suspected transactions.

3. chailease finance and fina finance had retained outside consultants kpmg for providing and analyzing risk-evaluation reports for the chailease conglomerate, as well as promulgating anti-money laundering and anti-terrorism policies, procedures and monitoring measures for all company divisions to follow since june 2018. the chailease finance and fina finance money laundering control act compliance plan was approved by the board of directors in october 2018. responsibility for implementing the compliance plan falls on the newly established money laundering control unit and its staff. internally, the unit monitors and reports suspicious transactions to competent authorities, and holds relevant training sessions, while serving as the company’s liaison with competent authorities.

4. in order to effectively implement anti-money laundering and anti-terrorism operations, and to meet international standards, the company purchased an aml computer system and database in may 2019. the dedicated units and related units will work with the system manufacturers to discuss more flexible and convenient settings that conform to international standards.

5. in order to fulfil the money laundering and terrorist financing supervisory requirements of various nations, the company drafted a money laundering and terrorism funding prevention policy at the holding company level and revised internal regulations. subsidiaries are also required to update money laundering and terrorist financing prevention guidelines in a manner that does not contravene the local laws in the nations in which they are registered. in response to revisions to the scope of taiwan’s money laundering control act adding financial leasing activities, chailease will do our utmost to coordinate with competent authorities. while fulfilling our corporate social responsibility, combating money laundering and terrorist financing, and minimizing costs, we will assist the taipei leasing association to consult with the competent authorities and consultants to complete the questionnaire and create a template.

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