(1) Our Code of Conduct:
All of us at Shoji Investor Relations Advisors LLC pledge to abide by the following code of conduct:
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.
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