Personal Information Protection Policy

Moriroku Technology Company, Ltd. (hereinafter referred to as "Company") believes that it is its social responsibility to properly protect the information provided to it that can identify individuals (hereinafter referred to as "Individuals") (hereinafter referred to as "Personal Information"). The Company will handle Personal Information in accordance with the following basic policies, and will endeavor to protect it. Among Personal Information, the Individual Number and Specific Personal Information (hereinafter referred to as "Specific Personal Information") shall be handled in accordance with the basic policy on the Proper Handling of Specific Personal Information, etc. separately provided.

1. Name of business operator

Moriroku Technology Company, Ltd.

2. Compliance with relevant laws and guidelines

The Company will comply with the Act on the Protection of Personal Information (Personal Information Protection Act) and other laws and regulations concerning the protection of Personal Information and privacy, as well as related ordinances, ministerial ordinances, and guidelines concerning the handling of Personal Information, Pseudonymously Processed Information, and Anonymously Processed Information (hereinafter referred to as "Personal Information, etc.").

3. Acquisition of Personal Information

The Company acquire Personal Information in a lawful and fair manner to the extent necessary for our business.

4. Purpose of Use

The Company will use the acquired Personal Information for the following purposes (hereinafter referred to as the "Purpose of Use") for the purpose of concluding and performing contracts, observing legal obligations, and providing for legitimate benefit or with the consent of the Individuals concerned.

• For providing products and/or services
• For providing, introducing or proposing information on products and/or services
• For introducing, providing or managing services ancillary to or related to the above
• For introducing events, etc.
• For developing new products and/or services
• For conducting recruitment activities, making contact or inquiries to retirees, conducting management or paying consideration with respect to patents or other intellectual property rights, and making other general administrative contact or inquiries
• For responding to inquiries and requests
• For smooth communication between personnel in charge of operations
• In order to carry out various procedures relating to personnel and labor management
• For preparing statistical materials
• In order to carry out other business incidental to (1) through (10) above or various measures to facilitate the relationship with our customers, employees, etc.

When acquiring Personal Information or handling Personal Information beyond the scope necessary for the achievement of the Purpose of Use, the Company shall obtain the consent of the Individuals concerned, unless such consent is no longer required by law. Note that the Individuals concerned may withdraw their consent at any time.
In addition, in the event the purpose of use is for the purpose of concluding and fulfilling a contract with the Individuals concerned and complying with legal obligations, it is necessary to provide the Personal Information of the Individuals concerned for the Purpose of Use.

5. Security control measures

The Company takes measures to properly manage personal data such as preventing leakage, loss, or damage of Personal Information as follows.

Formulation of Basic Policies

• This Protection Policy has been established to ensure the proper handling of Personal Information and to notify the contact point for questions and complaint handling.

Establishment of Rules on the Handling of Personal Data

• Formulate rules for the handling of Personal Information for each stage of acquisition, use, storage, provision, deletion, disposal, etc., with respect to the handling methods, supervisors, persons in charge, and their duties, etc.

Organizational Safety Management Measures

• Personal Information Control Supervisors, who have overall responsibility for the handling of personal data, and Affairs Handling Supervisors, who are responsible for the handling of Personal Information, are appointed.
• Clarify the scope of personal data handled by employees and employees handling personal data.
• Establishment of a system to notify the Personal Information Control Supervisors of any fact or sign of violation of laws or internal regulations
• Periodically conduct self-inspections of the status of the handling of Personal Information by the Affairs Handling Supervisors and conduct audits by the internal audit division

Measures for Human Security Management

• Periodic training for employees on matters to be noted regarding the handling of Personal Information
• Matters concerning the confidentiality of Personal Information are described in the Work Regulations.

Physical Safety Management Measures

• In areas where Personal Information is handled, measures are implemented to control the entry and exit of employees and to restrict devices etc. brought in, and to prevent unauthorized persons from accessing Personal Information.
• Take measures to prevent theft or loss of equipment, electronic media, documents, etc. handling Personal Information.
• Take measures to prevent Personal Information from being easily identified when carrying devices, electronic media, etc. that handle Personal Information, including moving within the business office.

Technical Safety Management Measures

• Implement access control to limit the scope of personnel in charge and Personal Information handled
• Introduced a mechanism to protect information systems that handle Personal Information from unauthorized access from outside or from unauthorized software.

Understanding of External Environments

• When Personal Information is stored in a foreign country, security control measures shall be implemented after understanding the system and rules of protection of Personal Information in the country concerned. In addition, periodic confirmation of systems and rules related to the protection of Personal Information in the country concerned is implemented.

6. Provision to third parties

In principle, the Company will not provide personal data to any third party except with the consent of the Individuals concerned or in accordance with laws and regulations. Provided, however, that in the event the handling of personal data is entrusted within the scope necessary for the achievement of the Purpose of Use, in the event of a merger, etc., or in the event of a joint use with a specified person as separately provided, personal data may be provided to a person other than us without obtaining the consent of the Individuals concerned.

7. Joint use

Our Group companies will share personal data held by each Group company and business tie-up company. For details, please refer to "Joint Usage by Moriroku Group and Business Alliance Companies."

8. Special care-required personal information

The Company will not acquire Special care-required personal information (such as personal information that includes race, creed, social status, medical history, criminal history, facts that have been injured by a crime, and other descriptions stipulated by laws and regulations as requiring special consideration for the treatment of the individual so as not to cause unjust discrimination, prejudice, or other disadvantages) unless the Company have obtained the prior consent of the Individuals concerned or pursuant to laws and regulations, etc.

9. Pseudonymously Processed Information

When creating Pseudonymously Processed Information, the Company take the following actions.

• Perform proper processing in accordance with the standards set forth by laws and regulations.
• Take safety management measures to prevent leakage of deleted information and information on processing methods in accordance with the standards stipulated by laws and regulations.
• To specify and publicize the Purpose of Use of the prepared Pseudonymously Processed Information
• Not to engage in any act to identify the Individual concerned with the Personal Information that was the source of the preparation

In the event of joint use of Pseudonymously Processed Information, the Company will share such information as described in "Joint Usage by Moriroku Group and Business Alliance Companies."

10. Anonymously Processed Information

When creating Anonymously Processed Information, the Company take the following actions.

• Perform proper processing in accordance with the standards set forth by laws and regulations.
• Take safety management measures to prevent leakage of deleted information and information on processing methods in accordance with the standards stipulated by laws and regulations.
• Publicize the items of information contained in the Anonymously Processed Information created.
• Not to engage in any act to identify the Individual concerned with the Personal Information that was the source of the preparation

In the event the Anonymously Processed Information is provided to any third party, the Company shall publicly announce the items of Personal Information contained in the Anonymously Processed Information to be provided and the method of provision thereof, and shall clearly indicate that the information to be provided to such third party to whom such information is provided is Anonymously Processed Information.

11．Handling of entrustment

The Company may entrust the handling of Personal Information to a third party. In this case, the Company will conduct necessary and appropriate supervision of the trustee in accordance with the applicable laws and regulations.

12．Disclosure, Correction, Deletion, etc. of Retained Personal Data

The Company will endeavor to respond appropriately and promptly in accordance with laws and regulations in the event that the Individual concerned or his or her agent requests disclosure, correction, or deletion of such Retained Personal Data, or refuses to use or provide such Personal Information. For specific requests and inquiries, please contact "14. Contact point for inquiries and complaint handling" below.

13. Continuous improvement

The Company strives to continuously review and improve the handling of Personal Information.

14. Contact point for inquiries and complaint handling

For inquiries or complaints regarding the handling of Personal Information and the preparation and handling of Anonymously Processed Information, please contact the following contact point.
The Personal Information Protection Committee and other supervisory agencies may be appealed against the handling of Personal Information.

Moriroku Technology Company, Ltd.
privacy@moriroku.co.jp

April 1, 2022

Moriroku Technology Company, Ltd.

Address: 1-1, Minami-Aoyama 1-chome, Minato-ku, Tokyo

Representative: Takashi Kurita, President and CEO

Basic policy on the proper handling of specific personal information, etc.

For the purpose of addressing the issue of ensuring the proper handling of personal numbers and specific personal information (hereinafter referred to as "Specific Personal Information, Etc.") by Moriroku Holdings Company, Ltd. (hereinafter referred to as the "Company"), the Company hereby sets forth the following basic policy to be applied towards the proper handling of Specific Personal Information, Etc.
Note that the Company will handle personal information other than Specific Personal Information, Etc. in accordance with the Personal Information Protection Policy stipulated separate of this policy, and will endeavor to protect said information.

1. Name of business operator

Moriroku Holdings Company, Ltd.

2. Adherence to related laws, ordinances, guidelines, etc.

The Company will adhere to laws and ordinances related to personal numbers and specific personal information, the guidelines set forth by the Specific Personal Information Protection Commission of Japan, and other norms (hereinafter referred to "Related Laws, Ordinances, Etc.").

3. Purpose of Use

The Company will use Specific Personal Information, Etc. provided to it for the following purposes.

• Specific Personal Information, Etc. belonging to business partners
  • Preparation duties for payment records regarding real estate transactions
  • Preparation duties for payment records regarding compensation, charges, contract monies and prize monies
• Specific Personal Information, Etc. belonging to shareholders
  • Preparation duties for payment records regarding dividends and distributions of surplus
• Specific Personal Information, Etc. of Company employees, etc.
  • Tax-related duties, etc.
    • Preparation duties for Certificates of Tax Deducted
    • Submission duties for reports, notifications and applications regarding property accumulation savings for house construction and property accumulation pension savings
    • Submission of information to employee stock ownership plan for preparation duties for payment records conducted by that plan for its members
  • Social insurance-related duties
    • Notification, application and billing duties for health insurance and welfare pension insurance
    • Notification, application, billing and certificate preparation duties for employment insurance and workers' compensation insurance
• Specific Personal Information, Etc. belonging to spouses, family members, etc. of Company employees, etc.
  • Tax-related duties
    • Preparation duties for Certificates of Tax Deducted
  • Social insurance-related duties
    • Notification duties for health insurance and welfare pension insurance

4. Matters pertaining to security control measures

The Company will set forth the organizational, human, physical and technological security control measures that it should take in order to ensure the proper handling of Specific Personal Information, Etc. in the form of internal regulations, and will adhere to said regulations.

5. Handling of consignment

The Company may consign the handling of Specific Personal Information, Etc. to a third party. In such cases, it will conduct the necessary and adequate supervision of the consignee in question in accordance with Related Laws, Ordinances, Etc.

6. Ongoing improvements

The Company will revise its handling of Specific Personal Information, Etc. on an ongoing basis and endeavor to improve that handling.

7. Disclosure of Specific Personal Information, Etc.

In instances where the persons in question or an agent thereof request the disclosure of personal data in the possession of the Company that pertains to Specific Personal Information, Etc., the Company will respond without delay with the exception of the cases stipulated below.

• • When there is a risk that harm will come to the lives, physical well-being, property or other rights or interests of the persons in question or a third party
  • When there is a risk that the proper implementation of the business of the Company will be hindered significantly
  • When a violation of a law or ordinance will occur as a result

8. Point of contact

The Company established a point of contact for inquiries, etc. regarding Specific Personal Information, Etc. and handles those inquiries, etc. through said point of contact.

Point of contact for inquiries, etc. regarding Specific Personal Information, Etc.

privacy@moriroku.co.jp

Joint Usage by Moriroku Group and Business Alliance Companies

In order to provide high-value-added services to stakeholders, the Moriroku Group will share the personal data held by each group company.
In addition, in the event of any change in the scope of joint users or the manager in charge of joint use, such change shall be notified to the Individual concerned in advance or shall be in a readily accessible condition.

• Items for shared usage
  Names, addresses, dates of birth, telephone and facsimile numbers, email addresses, information on places of affiliation, information on the content of contracts with Moriroku Group companies and/or business partner companies, product sales information, and the content of information provided or inquiries received
• Scope of joint users
  Moriroku Holdings Company, Ltd.
  Moriroku Chemicals Company, Ltd.
  Shikoku Kakoh Co., Ltd.
  Moriroku Agri Co., Ltd.
  Goko Kasei Industrial Co., Ltd.
  Yukou Co., Ltd.
  Kumamoto Moriroku Kasei Co., Ltd.
  I.M. MATERIAL Corporation
• Purpose of Use
  • For providing products and/or services carried by Moriroku Group companies
  • For providing, introducing or proposing information on products and/or services carried by Moriroku Group companies
  • For introducing, providing or managing services ancillary to or related to the above
  • For introducing events, etc. by Moriroku Group companies
  • For developing new products and/or services
  • For conducting recruitment activities, making contact or inquiries to retirees, making contact or inquiries to shareholders, conducting management or paying consideration with respect to patents or other intellectual property rights, and making other general administrative contact or inquiries
  • For handling inquiries, requests, etc.
  • For preparing statistical materials
• Managing supervisor of shared usage
  Moriroku Holdings Company, Ltd.
  Address: 1-1, Minami-Aoyama 1-chome, Minato-ku, Tokyo
  Representative: Takashi Kurita, President and CEO

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