Acom : Internal Control Report(102KB)

[Cover]
[Document Submitted]	Internal Control Report
[Article of the Applicable Law Requiring	Article 24-4-4, Paragraph 1 of the Financial Instruments and
Submission of This Document]	Exchange Act of Japan
[Submitted to]	Director, Kanto Local Finance Bureau
[Date of Submission]	June 23, 2023
[Company Name]	ACOM Kabushiki-Kaisha
[Company Name in English]	ACOM CO., LTD. (the "Company")
[Position and Name of Representative]	Masataka Kinoshita, President & CEO
[Position and Name of	―
Chief Financial Officer]
[Location of Head Office]	9-1, Higashi Shinbashi 1-chome,Minato-ku, Tokyo
[Place Where Available for Public	Tokyo Stock Exchange, Inc.
Inspection]	(2-1, Nihombashi Kabutocho, Chuo-ku, Tokyo)

This document is a translation of the Internal Control Report (original text: Japanese) submitted to the Prime Minister pursuant to Article 24-4-4 of the Financial Instruments and Exchange Act. It does not bear any responsibility pertaining to the aforementioned Financial Instruments and Exchange Act regarding the content of the English text. We recommend that the determination of the authenticity of the content be based on the Japanese text of the Internal Control Report.

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1 Matters concerning the basic framework for internal control over financial reporting

Masataka Kinoshita, President & CEO, is responsible for establishing and maintaining internal control over the Company's financial reporting, and he establishes and maintains internal control over financial reporting in line with the basic framework for internal control set forth in "On the Setting of the Standards and Practice Standards for Management Assessment and Audit Concerning Internal Control Over Financial Reporting (Council Opinions)" released by the Business Accounting Council.

Internal control seeks to achieve its goals within a reasonable range through the organic linking and integrated functioning of the basic elements of internal control. Accordingly, it is possible that internal control over financial reporting cannot fully prevent or discover the inclusion of misstatements in financial reports.

2 Matters concerning assessment scope, reference date, and assessment procedures

Internal control over financial reporting has been assessed using March 31, 2023, the last day of the current fiscal year examined, as the reference date, and generally accepted standards for assessment of internal control over financial reporting were applied in making this assessment.

After assessing internal control (companywide internal control) having a significant impact on overall financial reporting on a consolidated basis, the operational processes to be assessed were selected in accordance with the results. To assess these operational processes, the selected operational processes were analyzed and the efficacy of internal control then evaluated by determining the essential aspects of control having a significant impact on the reliability of financial reporting and assessing the establishment and maintenance of these essential aspects.

The required scope for assessing internal control over financial reporting at the Company, its consolidated subsidiaries, and equity-method affiliate was determined on the basis of the significance of the impact on the reliability of financial reporting. The significance of the impact on the reliability of financial reporting was itself determined from the perspectives of monetary and qualitative impact, and the scope for assessing internal control over operational processes was then determined rationally based on the results of assessments of companywide internal control conducted at the Company and four consolidated subsidiaries. Equity-method affiliate was not included in the scope of assessment of companywide internal control from the perspectives that it does not have monetary and qualitative impact.

In deciding on the scope for assessing internal control over operational processes, the top two-thirds of locations in terms of operating revenue (before the elimination of transactions between consolidated companies) for the consolidated fiscal year were selected as "key business locations." At the selected key business locations, operational processes were assessed for accounts highly relevant to the company's business objectives, including operating revenue, accounts receivable - operating loans, loans payable, and bonds payable relating to fund procurement. Furthermore, operational processes pertaining to major accounts containing estimates and forecasts for which there exists a high possibility of critical misstatements as well as operational processes connected with operations involving high-risk transactions were additionally assessed as key operational processes due to their impact on financial reporting.

3 Matters concerning assessment results

The aforementioned assessments determined that the Company's internal control over financial reporting was effective as of the last day of the current fiscal year examined.

1. Additional matters Not applicable
2. Matters on special note Not applicable

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