Employment ＆ Procurement

The Institute for Global Environmental Strategies (hereinafter, the Institute) is committed to avoid directly and indirectly being involved in or supporting money laundering, financing terrorist activities, or other criminal misuse of funds. This Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) Policy (hereafter, the Policy) outlines the principles and basic framework of internal AML/CFT controls by the Institute. As a non-profit organisation operating in Japan and overseas, there is a risk of the Institute’s operations being misused by individuals or other organisations to launder money, to finance and support terrorist activity, or to be misused by other criminals or criminal organisations. The Institute considers compliance with AML and CFT laws, and with the Institute’s internal policies relating to them, to be a serious matter, and will make all possible efforts to ensure that its operations are sound and appropriate.

This Policy applies to the Institute’s Executive Management, all staff, and any persons working on the Institute’s behalf or for its benefit. The Executive Management, all staff and those working on the Institute’s behalf or for its benefit must abide by all AML and CFT laws and regulations enforced by government agencies applicable to any jurisdiction in which the Institute conducts activities. Anyone who does not comply with such laws and policies may be subject to disciplinary action, up to and including termination of their employment or other relationship with the Institute.

1. Money laundering refers to: (a) the conversion or transfer of property, knowing that such property is derived from crime, for the purpose of concealing or disguising the illicit origin of the property or assisting any person who is involved in the commission of the crime to evade the legal consequences of his or her actions; (b) concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of property, knowing such property is derived from crime; or (c) acquisition, possession or use of property, knowing at the time of receipt that such property was derived from a criminal offence.1
2. Terrorism/terrorist act refers to any violent act, or a threat to commit such an act, that is done with the intention to coerce or influence a civilian population or government through intimidation.2
3. Executive Management refers to full-time Directors of the Institute.

1. The Institute’s policy and systems must be consistent with the requirements and recommendations of the relevant international organisations and the laws/regulations of relevant countries including those set in Japan for ensuring that no business transactions are made with anti-social forces or individuals.
2. The Institute must adopt and implement a risk-based approach to identify, assess, understand, and reduce its ML and TF risks by applying the Institute’s “Know-Your-Customer” requirement in due diligence and other related AML/CFT procedures. The Institute must completely sever any connections or relations with anti-social forces, repudiate any unjustifiable claims, not engage in any “backroom” deals and promptly take legal action as necessary, and appropriately respond as an organisation to any anti-social forces by cooperating with outside professionals.

1. Executive Management: The Executive Management is responsible for ensuring governance and oversight of the Institute’s risk management framework and controls regarding ML and FT.
2. Strategic Management Office (SMO): The SMO cooperates to ensure effective implementation of this Policy, with responsibilities allocated in accordance with their respective mandates.
3. Staff and those working on the Institute’s behalf or for its benefit are responsible for:
   1. Complying with the Institute’s AML/CFT policy and procedures;
   2. Familiarising themselves with and acting in accordance with relevant Institute’s processes and procedures to manage AML/CFT compliance; and
   3. Reporting to the SMO without undue delay any suspicions (or actual occurrences) or red flags of ML/TF activities.

The Institute will implement the following procedures to manage AML/CFT risks with reference to the recommendations and other related information published by the United Nations, the Financial Action Task Force (FATF), Japan Financial Intelligence Center (JAFIC)3 and others.

1. Due diligence　(Contents are being discussed internally)
   1. The Institute recognises Customer Due Diligence (CDD) as the most important element in the AML/CFT measures, considering the type of customer, customer relationship, and country of operation. The Institute will apply the CDD procedures prior to making business arrangements (contracting, etc.) or transactions.
   2. The Institute will identify and verify the identity of its customers (including their beneficial owners and/or superiors when applicable) with which the Institute enters into a counterparty relationship with reasonable means including the following but not limited to:
      • Screen the customers and their beneficial owners using the latest information about High-Risk Jurisdictions subject to a Call for Action, Politically Exposed Persons (PEPs), the organisations or companies under suspension of operations, and other relevant information.
      • Check against negative information about the customers from media or public authorities (government agencies, etc.) or confirm with the recommendations/referrals for the customers provided by the government agencies in the project countries, the Institute’s partner organisations or other trusted sources.
      • Request rational explanations and evidence from the customer if the information about the customer (contents of business, location, etc.) is deemed to be irrational in light of the purpose of transactions.
      • When this Policy cannot provide a specific response for every circumstance, the Institute will use its best possible sound judgment in relation to the case, and will document clearly the decisions made and the reasons behind them.
      • This Policy will be included in all contracts and related forms of the Institute. The Policy will be also made available to public (through the Institute website), and the materials that help raise awareness of the issue will be shared with Executive Management and staff.
2. Monitoring, Reporting and Review
   1. All transactions by or through the Institute (Executive Management, staff, and those working on the Institute’s behalf or for its benefit) will be monitored to ensure they are not in breach of this Policy. For overseas transfer and payment, the Institute will confirm the payee’s bank account information with the bank that the Institute uses, and such transactions will be made only by the designated personnel in SMO once all necessary approvals are given.
   2. If any suspicious information (or red flag) that comes to the attention of Executive Management or staff, including potential misconduct, any such information from the Institute’s internal inspection by the auditor, or any such information related to cyber fraud alerts, then they must immediately report this information to SMO. The SMO will conduct an internal investigation to assess the information and respond to mitigate any associated risks under the supervision of Executive Management, based on the Institute’s regulations and procedures.
   3. The Institute will review and examine its AML/CFT Policy and maintain effective implementation of the AML/CFT Policy for the Institute. Reviews will be undertaken by the Executive Management in line with new recommendations made by relevant authorities overseas or in Japan.
3. Confidentiality

   The Institute will ensure all information on customers and transactions obtained while fulfilling AML/CFT requirements is kept confidential.