Handling of personal information

1. Acquisition of personal information and purposes of use

IR Japan, Inc. (hereinafter, the “Company”) acquires and uses personal information to an appropriate extent, in accordance with the following purposes of use. If it becomes necessary to use personal information for purposes other than those listed below, the Company will obtain the consent of the individual to whom the information pertains, except in cases where the individual has given prior consent or where exceptions are permitted under the Act on the Protection of Personal Information or other laws and regulations. In addition, the Company may outsource a part of its business to a contractor and entrust personal information to the contractor to the extent necessary. In such cases, we will appropriately manage personal information in accordance with laws and regulations as well as standards prescribed by the Company.

① Personal information of persons in charge of exercising voting rights and other institutional investors (investment management institutions)

• To provide the following services of the Company:
  • Provision of Large Volume Holding Reports Search System Service (Stock Watch)
  • Provision of Domestic and Overseas Institutional Investors’ Ownership Viewing Service (Domestic and Overseas Fund Stock Watch) based on investment trust management reports, prospectuses, fund management status reports, stockholding information disclosed by non-U.S. overseas funds, information on persons in charge of exercising voting rights and other information disclosed by institutional investors (investment management institutions)
• To provide useful services of the Company to persons in charge of exercising voting rights and other institutional investors (investment management institutions) for the purpose of facilitating appropriate and smooth dialogue with shareholders regarding engagement between other issuer companies and persons in charge of exercising voting rights/other institutional investors (investment management institutions) in connection with the above services

② Personal information obtained from contractors or consignors

• To manage contractors
• To perform the services entrusted by consignors

③ Personal information of inquirers

• To respond to the inquiry selected in the inquiry item

④ Personal information obtained from public information

• To conduct surveys to improve the quality of its overall services and introduce the Company’s services
• To confirm the information in accordance with laws and regulations and to manage ongoing transactions

⑤ Personal information of applicants for IR briefing information distribution services

• To provide Analyst Network and other services for potential investors that provide useful information to analysts and institutional investors, such as information on the Company’s services and corporate IR briefings, financial results and general meetings of shareholders

⑥ Personal information of clients pertaining to financial instruments handling business

• To keep records including personal information in accordance with laws and regulations and to manage the Company’s transaction records, etc.
• To provide information related to financial instruments handling business and propose financial products
• To confirm identity and eligibility, etc., to use financial services in accordance with laws and regulations
• To manage ongoing transactions, such as due date management for financial instruments handling business
• To make decisions regarding continued use of financial instruments handling business and other matters
• To exercise rights and fulfill obligations based on contracts with applicants, etc. and laws, etc.
• To make decisions according to the principle of suitability, etc. and other decisions on the appropriateness of providing financial instruments handling business
• To understand and manage various risks and to smoothly execute transactions with applicants, etc.
• To use the Individual Number (“My Number”) in preparing and providing statutory documents relating to financial instruments transactions in accordance with the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures

⑦ Personal information of candidates for outside directors in the Company’s service: Independent Outside Director Search

• To introduce candidates to companies that have job openings that we have offered candidates
• To introduce candidates to companies that have specific job openings held by recruiting firms with whom we have entered into non-disclosure agreements, through such recruiting firms
• To communicate and confirm matters related to each of the above two items
• To inform applicants (candidates) of our services or those of our business partners that may be useful to applicants (candidates) by email or post, etc.

⑧ Personal information of users who wish to register for Candidate Simulation

• To provide outside director candidate simulation services
• To respond to inquiries relating to Independent Outside Director Search
• To inform applicants by email or post, etc., of company briefing sessions and surveys, etc., planned by the Company
• To provide other information by email or post, etc., on the Company’s services and corporate IR information that may be useful to prospective users

⑨ Personal information of Kabunushi-Hiroba service users

• To notify users of various surveys
• To tabulate and process survey results
• To send information on company briefing sessions, etc., to users
• To send rewards to thank users for cooperating with surveys
• To send gifts, etc., in response to entering prize competitions, etc.

⑩ Personal information of applicants for IR tool joint production partners

• To process procedures for screening, credit checks and other checks required by laws and regulations, and to initiate transactions

⑪ Personal information of applicants for employment

• To provide information on various company information sessions and to accept applications
• To provide various company information and details of employee recruitment
• To conduct selection process for recruitment
• To notify the applicant of the results of the recruitment selection process

⑫ Personal information of employees, resignees and retirees

• To manage personnel and payroll
• To provide internal services and benefits
• To perform labor safety and health management operations
• To communicate in the course of business and in case of emergency, such as in the event of a disaster
• To manage the health of employees in accordance with laws and regulations
• To conduct business management, asset management, system management, etc.
• To comply with labor-related laws and regulations for resignees and retirees
• To contact resignees and retirees for administrative purposes or in case of emergency
• To conduct various other activities to contribute to operations incidental and related to the above

2. Provisions for joint use

① Joint use of information

In addition to business management and risk management of the entire group centered on IR Japan Holdings, Ltd. (hereinafter, the “Group”), the Company conducts the following joint use to provide higher value-added services that take advantage of the characteristics of each Group company.

② Items of personal information to be jointly used

• All information described in 1. ① to ⑧, ⑪ and ⑫ above
  　Name, information related to affiliation (company name, department name, etc.), title, address, telephone number, fax number, email address, etc., and any information arising from transactions, discussions, negotiations, etc.
• All information on business cards received by the Company
  　Name, information related to affiliation (company name, department name, etc.), title, address, telephone number, fax number, email address, etc.

③ Scope of joint users

IR Japan Holdings, Ltd.

Group companies of IR Japan Holdings, Ltd.

https://www.irjapan.jp/en/group/

④ Purpose of use by joint users

• To properly execute business management and various risk management of the Group
• To plan and develop higher-quality products and services offered by the Group
• To provide individualized proposals and information regarding the Group’s various products and services

⑤ Responsibility for the management of personal information to be jointly used

Senior General Manager, Administration Department, IR Japan, Inc.
*Please check “8. About Our Organization” for the address and name of the representative.

⑥ Method of acquisition

The Company acquires the personal information described in 2.② in writing and in electronic data.

3．Provision of personal data to third parties in accordance with Article 27, Paragraph 2 of the Act on the Protection of Personal Information and JIS Q 15001

The Company may provide users of its Large Volume Holding Reports Search System Service (Stock Watch) and the Domestic and Overseas Institutional Investors’ Ownership Viewing Service (Domestic and Overseas Fund Stock Watch) with the personal data of persons submitting large volume holding reports, holders, institutional investors and persons in charge of exercising voting rights as follows, to the extent necessary to provide each service. The Company has filed a notification and made a public announcement to such effect in accordance with Article 27, Paragraph 2 of the Act on the Protection of Personal Information.

With respect to the provision of personal data to third parties for each service, the Company will suspend provision of personal data that identifies the person in question to third parties at their request. With respect to persons who wish provision to be suspended, the Company will immediately take measures to suspend provision if a request is made to the “7. Personal information protection contact point” in accordance with the following procedures.

(1) Large Volume Holding Reports Search System Service (Stock Watch)

• Purpose of provision

  Search and view large volume holding reports (Article 27-23 of the Financial Instruments and Exchange Act)

• Items of personal data provided to third parties

  Submitter

  Name of submitter, total number of issued shares, number of shares held, ownership ratio, ownership ratio fluctuation range, total amount acquired, date of reporting obligation, date of submission, name of issuing company, securities code, name of document submitted

  Holder

  Name of holder, total amount stipulated in the main text of Financial Instruments and Exchange Act Article 27-23, Paragraph 3^*1, total amount stipulated in Article 27-23, Paragraph 3, item i^*2, total amount stipulated in Article 27-23, Paragraph 3, item ii^*3, deducted share certificates, number of deducted shares among joint holders, number of shares held, number of potential shares held, ownership ratio, ownership ratio fluctuation range, funds for acquisition

  1. The total amount stipulated in the main text of Financial Instruments and Exchange Act Article 27-23, Paragraph 3 indicates the total of share certificates, etc. (share certificates, subscription warrants, share option certificates, corporate bond certificates with share options, subject securities cover warrants, share certificate depositary receipts, share certificate-related depositary receipts, subject securities redemption bonds, and the same applies hereinafter) held by a person that has acquired share certificates, etc., in their own names or in the name of another person (or under a fictitious name)(including a person that holds the right to request the delivery of share certificates, etc., under a purchase and sale contract or any other contract) in accordance with the main text of Article 27-23,Paragraph 3 of the Financial Instruments and Exchange Act.
  2. The total amount stipulated in Financial Instruments and Exchange Act Article 27-23, Paragraph 3,item i indicates the total of share certificates, etc., held by a person that has the authority to exercise voting rights as a shareholder of the company that is the issuer of the share certificates, or to give instructions as to the exercise of those voting rights, based on a money trust contract or any other contract or the provisions of laws and regulations, and that has the aim of controlling the business activities of said company, in accordance with Article 27-23, Paragraph 3, item i of the Financial Instruments and Exchange Act.
  3. The total amount stipulated in Financial Instruments and Exchange Act Article 27-23, Paragraph 3, item ii indicates the total of share certificates, etc., held by a person that has the necessary authority to invest in share certificates, etc., based on a discretionary investment contract or any other contract or the provisions of laws and regulations, in accordance with Article 27-23, Paragraph 3, item ii of the Financial Instruments and Exchange Act.
• Method of provision to third parties

  Email to members, IR-Pro online service for members (internet-based service)

• Method of acquisition

  Acquisition from the Financial Services Agency’s Electronic Disclosure for Investors’ NETwork (EDINET)

(2) Domestic and Overseas Institutional Investors’ Ownership Viewing Service (Domestic and Overseas Fund Stock Watch)

• Purpose of provision

  Search and view investment trust management reports, prospectuses, fund management status reports, stockholding information disclosed by non-U.S. overseas funds, information on persons in charge of exercising voting rights and other information disclosed by institutional investors (investment management institutions), and stock inclusion information prepared by the Company based on such information

• Items of personal data provided to third parties

  Name and title of the persons in charge of exercising voting rights, funds under management

• Method of provision to third parties

  IR-Pro online service for members (internet-based service)

• Method of acquisition

  Acquisition of information disclosed by various investment management institutions through various media