Liberty Exchange JAPAN Co., Ltd. (hereinafter referred to as "our company") establishes the following basic policy (hereinafter referred to as "this policy") to implement a system risk management framework, intended to mitigate the risk of losses to customers and our company due to malfunctions or misuse of information systems within the services provided by our company.

1.Scope of Application

This policy applies to all information systems utilized for cryptocurrency-related transactions by our company, as well as any information systems owned or utilized for the company's operations.

2.Applicable Individuals

This policy applies to our company's directors, employees, temporary staff, and contractors of our company.

3.Framework for System Risk Management

Our company designates specific departments and individuals responsible for managing information systems to address and mitigate system risks. We establish the necessary organizational structure and conduct regular audits to ensure compliance with this policy, management rules, and the effectiveness of system risk management. Any necessary remedial measures are taken accordingly.

4.Establishment of Regulations for System Risk Management

Our company formulates management rules concerning system risks and appropriately identifies and evaluates system risks in accordance with these rules. All directors and employees of our company comply with these management rules.

5.Management of Contractors

When our company outsources system-related work, we conduct necessary and appropriate supervision to ensure that the contractor's system management is performed appropriately, based on related laws and regulations, this policy, and management rules.

6.Implementation of Education and Training

Our company ensures that all directors and employees are well-informed about this policy and related regulations. We regularly provide necessary education and training on system risks to enhance awareness and understanding.

7.Continuous Improvement of Basic Policy

To ensure comprehensive risk management, including system risks, our company continually reviews and enhances this policy.