Confidentiality Policy

Introduction

Japan EHS Audit Co., Ltd. (hereinafter referred to as "the Company") recognizes all information entrusted to us by customers in conducting audit and consulting business related to EHS and ESG as top-priority confidential information. Building trust with customers is the foundation of our business, and we believe that maintaining the confidentiality of entrusted information is our absolute social responsibility. To fulfill this responsibility, the Company establishes the following Confidentiality Policy and declares that all officers, employees, and related parties involved in our business will comply with it.

Article 1 (Definition of Confidential Information)

In this policy, "Confidential Information" refers to all technical, sales, financial, and other information of the customer that the Company receives from the customer or learns in the course of business execution. This applies regardless of the means of disclosure (written, oral, electromagnetic recording media, etc.) or whether the information is indicated as confidential.

Article 2 (Handling of Confidential Information)

1. Prohibition of Use for Unintended Purposes

The Company will not use Confidential Information disclosed by the customer for any purpose other than to execute business based on the contract with said customer.

2. Non-disclosure to Third Parties

The Company will strictly manage Confidential Information disclosed by the customer and will not disclose or leak it to third parties without the prior written consent of the customer.

3. Security Control Measures

To prevent leakage, loss, or damage of Confidential Information, the Company will take appropriate organizational, human, physical, and technical security control measures based on our Information Security Policy.

Article 3 (Exceptions to Confidentiality Obligation)

Notwithstanding the provisions of the preceding article, the Company shall not bear a confidentiality obligation for information falling under any of the following:

1. Information that was already in the public domain at the time of disclosure

2. Information that became public domain through no fault of the Company after disclosure

3. Information that was already legitimately possessed by the Company at the time of disclosure

4. Information legitimately obtained from a third party with legitimate authority without confidentiality obligation

5. Information independently developed by the Company without relying on disclosed Confidential Information

6. Information required to be disclosed based on laws or orders from courts, government agencies, etc. However, in the event of receiving such an order, the Company shall endeavor to promptly notify the customer.

Article 4 (Handling after Contract Termination)

Even after the termination of the contract with the customer, the confidentiality obligation defined in this policy shall remain valid. Furthermore, upon request from the customer after contract termination, we will promptly return or dispose of the entrusted Confidential Information in accordance with the customer's instructions.

Article 5 (Supervision of Officers and Employees)

The Company will provide appropriate education and supervision to our officers, employees, and partners to ensure compliance with this policy. We also impose equivalent confidentiality obligations on all persons involved in our business.

Article 6 (Review of Policy)

The Company will continuously review the content of this policy in response to amendments to laws and changes in social conditions and strive for improvement.

End

Established: August 1, 2025