Basic policy on protection of personal information

Mercuria Holdings Co.,Ltd. ("We" or "Us") and its officers and employees will observe the Act on the Protection of Personal Information, Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure and other applicable laws and ordinances, and hereby prescribe our basic policy on the protection of personal information as follows.

1. We will observe laws, ordinances and other rules related to the protection of personal information in respect to personal information including Specific Personal Information (Personal Information, etc.).

2. We will properly acquire Personal Information, etc. and will not use personal information beyond the scope of purpose of use. Furthermore, we will not disclose or provide Personal Information, etc. to a third party without obtaining the person's consent unless such disclosure is required under laws and ordinances.

3. We will endeavor to maintain the acquired Personal Information, etc. to be accurate and up to date. We will also take necessary and appropriate security control measures to prevent the unauthorized access, divulgence, loss and falsification of Personal Information, etc.

4. If we are to consign the handling of Personal Information, etc. to a third party, we will appoint a party that is acknowledged as being capable of properly handling Personal Information, etc., and appropriately supervise such party so that the security control measures of Personal Information, etc. are taken.

5. We will educate our officers and employees on the importance of protection of Personal Information, etc. by offering training, etc. Furthermore, we will supervise our officers and employees so that Personal Information, etc. is handled appropriately.

6. When requested by the person, we will disclose, correct or discontinue the use of Personal Information, etc. in accordance with laws and ordinances. In the foregoing case, we may charge a certain fee to the person.

7. We will prescribe our internal rules related to the protection of personal information, and continuously review and observe the same.

Purpose of use of personal information

We will handle personal information only to the extent required for achieving the following purposes of use.

1. To exercise our rights and fulfill our obligations under the Companies Act
2. To provide our shareholders with information and services
3. To compile statistical data and other information necessary for our public relations and investor relations activities.
4. Individual Number will be handled only to the extent permitted by law
5. The personal information of our officers and employees will be used for employment management, execution of duties based on related laws and regulations, and promotion of business activities

In accordance with laws and regulations, sensitive information will not be used or provided to third parties for purposes other than those deemed necessary for the proper operation of our business.

Shared Use of Personal Information

We may share personal information with our group companies in order to jointly carry out operations that we are able to perform or that are incidental to those operations.

1. Personal Information Shared
   We will use customer information such as name, address, date of birth, telephone number, and transaction needs, but will limit it to the minimum necessary items.
2. Scope of Shared Users
   Consolidated subsidiaries listed in our securities reports, etc.
3. Purpose of Use
   ・To conduct business management and internal control, such as integrated compliance and risk management of group companies
   ・Regarding personal information of our officers and employees, for employment management, execution of duties based on related laws and regulations, and promotion of business activities
4. Party Responsible for Management of Relevant Personal Information
   Mercuria Holdings Co., Ltd.

Personal Information Consultation

If you have any questions regarding our company’s handling of personal information, please contact our inquiry desk.

Basic Policy on the Proper Handling of Specific Personal Information, etc.

In compliance with the Act on the Use of Numbers to Identify Specific Individuals in Administrative Procedures and other laws and regulations, we have established the following basic policy for the appropriate handling of personal numbers and specific personal information (hereinafter referred to as "specific personal information, etc.")

1. Company Name

Mercuria Holdings Co., Ltd.

2. Appropriate Handling of Specific Personal Information, etc.

We will handle specific personal information, etc. in an appropriate manner in compliance with the Act on the Use of Numbers to Identify Specific Individuals in Administrative Procedures, the Act on the Protection of Personal Information, the Guidelines for the Appropriate Handling of Specific Personal Information (Company Edition), and other related laws, regulations, and guidelines.

3. Security control measures

We will prescribe our internal rules on the protection of Specific Personal Information, and take appropriate security control measures to prevent the unauthorized access to the Specific Personal Information, etc., and to prevent the divulgence, loss or damage of the Specific Personal Information, etc.

4. Consignment of handling of Specific Personal Information, etc.

We may consign the handling of Specific Personal Information, etc. to a third party. In the foregoing case, we will confirm that the consignee is taking the same level of security control measures as us, and offer necessary supervision to the consignee based on laws and ordinances.

5. Continuous improvement

We will continuously review and observe our internal rules so that the Specific Personal Information, etc. is protected appropriately.

6. Inquiry counter

Please contact our inquiry counter if you have any inquiries or requests concerning our handling of personal information.

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