Guidelines for Personal Information Protection

Shimamoto Partners has been in the management consulting business supporting both organizational and human resources growth of our clients’ businesses since its establishment in 1997. In consulting business, we believe confidentiality is one of the most important professional responsibilities. We have been complying with this obligation by setting a guideline for confidentiality and promoting a strict ethical standard for personal information acquired through our business practices.

With the Personal Information Protection Act and other related laws and regulations becoming in effect, we renewed our awareness that protection and management of personal information is our fundamental corporate responsibility and developed a new guidelines to enforce Personal Information Protection.

We are determined to follow these guidelines and to comply with laws and regulations set for Personal Information Protection. We will also continue to make our best effort to take necessary measures regarding personal information in the future.

1.Definition of “Personal Information”

“Personal Information” means information relating to living individuals which identify specific individuals by name, date of birth, address, career history, phone number, easily-retrievable numbers/signs assigned to individuals such as email addresses, or audio/visual data. All of the information, which can identify specific individuals, provided by document, email, website, and verbal means and collected through our search process or generated in order to provide our service is considered as “Personal Information”.

2.Purpose of Collecting Personal Information

The purpose of collecting “Personal Information” of individuals is for us to conduct management consulting business including management consulting, executive search, and nonexecutive board search services to our clients. We utilize “Personal Information” for the purpose of providing our services and conducting related activities within the business premises. Specifically, we present information of potential candidates to our clients including name, career history (name of employer and position), academic history, skills, and date of birth of those candidates in order to introduce and recommend the candidates for specific positions at the client company in the form of documents, data, and verbal means. However, if and when any individual requests not to disclose their Personal Information to a third party, we immediately cease to provide the personal data. Please contact the officer stated below responsible for Personal Information Protection. In addition, please note that aside from the above purpose, we may use the Personal Information to offer business publication, to provide information on conferences and seminars, or to contact for business development or consultation.

3.Discloser of Information to Third Parties

We consider Personal Information provided by each individual as very important information and we are determined to utilize the information only within the purpose of its collection. Therefore, except for the purpose of providing information to our clients as stated in section 2 of this document or unless otherwise stipulated by law, we do not disclose the information to a third party without consent from the individual beforehand.

4.Disclosure, Correction, and Deletion of Personal Information

With regard to disclosure, correction and deletion of Personal Information provided by an individual, we are determined to act immediately upon request subject to confirmation of identification of the requesting individual. Please contact the following officer regarding such cases.

Officer of Personal Information Protection

Kazushige Hata, President of Shimamoto Partners

Contact:privacy@shimamotop.com

5.Effort to Protect Personal Information and Review of Guideline

In order to apply thorough security control measures for Personal Information and to prevent any leaks or illegal access of Personal Data, we maintain an internal control system, supervise our employees by appointing the Officer of Personal Information Protection and continue to conduct necessary measures to ensure protection.

We are determined to review and improve our measures accordingly.

Kazushige Hata
President
Shimamoto Partners