Our Policies

Our Pledge:

(1) Our Code of Conduct:

All of us at Shoji Investor Relations Advisors LLC pledge to abide by the following code of conduct:

1. We will maintain integrity and credibility in accordance with the highest professional, legal, moral and ethical standards.
2. We will not commit any professional misdeed, nor engage in unethical, questionable or inappropriate behavior, nor become involved in dubious or illicit business situations.
3. We will undertake our professional responsibilities completely and utterly to the highest global standards of competence.
4. We will maintain confidentiality of all information acquired during the course of our work, not just during a project but also after a project is completed.
5. We will not use confidential and insider information acquired during the course of our work for personal advantage, nor for the advantage of family members, professional or other related parties.
6. We will exercise independent, objective and neutral judgment, and provide constructive criticism in carrying out our duties and responsibilities, in order to steer our customers, shareholders, stakeholders, partners and other potential beneficiaries toward the best potential outcomes.
7. We will, at all times, conduct ourselves in a reputable and dignified manner that reflects the highest global standards of our profession.
8. We will avoid any professional, personal or other relationships that might affect, or be perceived to potentially affect, our ethical conduct.
9. We will honor our obligations to serve the best interests of our customers, shareholders, stakeholders, partners and other potential beneficiaries for the good of society and the world.

(2) Our Privacy Policy for Personal Information Protection

All of us at Shoji Investor Relations Advisors LLC recognize that personal information is an important asset protected by law. Thus, as part of our corporate social responsibility, we undertake rigorous control and protection of such information. As an enterprise that provides advisory services with security and safety, we have a privacy policy for handling personal information of our customers, business partners, officers, employees, and so on.

Through utmost care, we will provide a safe and secure operating environment for our clients in executing our advisory services. All of us at Shoji Investor Relations Advisors LLC pledge to abide by the privacy policy and to protect personal information as detailed below.

1. Compliance with laws and other regulations regarding personal information protection
We will comply with the laws, other regulations and guidelines of Japan concerning personal information protection.

2. Definition of personal information
“Personal information” under our basic policy refers to the following descriptions on individuals:
Name, date of birth, and other items included in the relevant information that can lead to identifying a particular individual.
Matters that can be cross-checked easily with other information so that it will lead to identifying a particular individual.

3. Control of personal information and continuous enhancement
In order to have proper protection of personal information, we have in place a system of rigorous controls. On an ongoing basis, all of us at Shoji Investor Relations Advisors LLC will take meticulous care and make continuous enhancements to these controls.

4. Implementation of information security
We have in place and enforce information security policies, to prevent risks of information leakage, falsification, and other undesirable mishaps.

5. Usage of personal information
Regarding the usage of personal information given to us, we will abide by the scope of purpose for usage that we have informed in advance.

6. Non-disclosure and non-transfer of personal information
We will neither disclose nor transfer personal information to a third party, except to authorized subcontractors, without the prior consent of the individual. However, when the court, the police, or other legal authority requests disclosure of personal information, Shoji Investor Relations Advisors LLC may disclose or transfer such personal information without the consent of the individual concerned.

Maroi Shoji

Principal

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