Policies on the Protection of Personal Information

Financial Partners Group Co., Ltd.

Statement on Safeguarding Personal Information

The business activities of Financial Partners Group Co., Ltd. (hereafter, “FPG”, “the Company” and “we”) hinge on the financial products trading business,real estate fund business,insurance sales business,trust agreement agency business, M&A business and FinTech business. Personal information collected from our clients in the course of executing these business activities and personal information about our executives and employees and their dependents (hereafter, collectively referred to as “personal information”) is vital to operations, and management recognizes that a concerted effort to safeguard personal information is an essential corporate social responsibility. Therefore, we will handle any personal information collected through our business activities in accordance with the following policies, and our commitment to protecting such information will not only give clients, executives and employees peace of mind but also fulfill our corporate duty.

Policies

1. Collecting, Using and Providing Personal Information

• ・We will collect personal information by lawful and fair means.
• ・We will use personal information only within the scope necessary to achieve the purpose of use.
• ・We will not provide personal information, except for Specific Personal Information, to a third party without the prior consent of the individual(s) concerned. We will not provide Specific Personal Information to a third party even if consented by the individual(s) concerned, except in cases that fall under any of the items of Article 19 of the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure.
• ・We will not use collected personal information for any use beyond the stated purpose.
• ・Should the need arise for personal information to be used beyond the stated purpose, we will obtain consent again for the revised purpose of use before actually using such information.

2. Laws, National Guidelines and other Standards (hereafter, “laws, etc.”)

We will strive to stay current on laws, etc. that pertain to operations involving the use of personal information, ensure that executives and employees engaged in our operations are aware of and comply with such laws, etc.

3. Security of Personal Information

• ・We will establish and maintain a system to expedite swift corrective measures, if/when necessary, to underpin the security of personal information and thereby prevent various risks to personal information, including unauthorized access, leaks, loss and destruction.
• ・We will perform inspections and immediately remedy any contravention or incident found. We will also implement pre-emptive measures to address weak points.
• ・We will provide thorough training for executives and employees to ensure the security of personal information.

4. Questions and Complaints

We will set up a point of contact for questions and complaints regarding our handling of personal information, establish and maintain a system to expedite actions if/when necessary, and respond with all sincerity to any questions and complaints that are brought to our attention.

5. Continuous Improvement

• ・To ensure proper handling of personal information (hereafter, “Proper Handing”), we will monitor and audit compliance with internal rules concerning Proper Handling, to find violation, incidents, accidents or weaknesses (if any), while the management revising or re-considering it accordingly.
• ・We shall then reflect it on our internal rules and administrative policies to improve corporate management structure to ensure Proper Handling, including this Privacy Policy, continually.

Hisanaga Tanimura
Representative Director-President
Financial Partners Group Co., Ltd.

Established on April 28, 2008
16th Edition: Amended on April 1, 2022

1. Person Responsible for Management of Personal Data at FPG

Personal Data Control Officer (Contact: See details under Contact Point for Questions and Complaints below.)

2. Purpose of Use

A. Purpose of Use of personal information except Specific Personal Information

Business Activities

• 1. Financial products trading business (securities trading, securities trading intermediary and services for handling private placement of securities) and associated operations.
  
• 2. Insurance agency business and associated operations.
• 3. M&A business and associated operations.
• 4. Real estate fund business (real estate specified joint enterprise and real estate brokerage)
• 5. Trust agreement agency business and associated operations.
• 6. Salary prepayment service and associated operations.

Purpose of Use

Type of Personal Information	Purpose of Use
Client information	(1) To solicit, sell, trade, broker and offer financial products, insurance products or trust products (collectively, “Financial Products”) in accordance with the Financial Instruments and Exchange Law, Insurance Business Law, Trust Business Act and any other applicable laws and to undertake the handling of private placements along with the introduction and provision of associated services. (2) M&A business and associated operations. (3) Real estate fund business (real estate specified joint enterprise and real estate brokerage) and associated operations. (4) Trust agreement agency business and associated operations. (5) Salary prepayment service and associated operations. (6) To confirm the identity of clients or their agents, in accordance with the Law to Prevent Transfer of Criminal Proceeds and miscellaneous related laws. (7) To confirm the authority of a corporate representative or its agent, when the client is a corporation. (8) To determine if the solicitation, sale, trade, brokering or offering of products, handling of private placements or introduction and provision of services is client-appropriate, in light of such standards as the principle of suitability. (9) To administer the process of contract execution with customers related to our services. (10) To exercise rights and fulfill obligations, in accordance with contracts and laws related to our services. (11) To ensure smooth and accurate execution of business with clients, including service-related communication connected with transactions as well as mailings, such as greeting cards. (12) To facilitate the cancellation of transactions and follow-up after a transaction has been cancelled. (13) To pursue research and development on financial products and services through market surveys, data analysis and questionnaires. (14) To present and explain financial products and services and introduce upcoming seminars organized by the Company through direct mail and other means of contact. (15) Concierge services and associated operations. (16) To present products and services offered by affiliated companies and other sources. (17) To respond to client inquiries and comments. (18) To ensure security of the Company, especially in regard to the use of information systems and access into facilities. (19) To properly execute services outsourced to us in such cases where we are entrusted with all or some personal information processing tasks by another company.
Referrer (accountants, tax advisers, etc.) information	(1) To introduce our Financial Products. (2) To introduce M&A business and associated operations. (3) To introduce real estate fund business (real estate specified joint enterprise and real estate brokerage) and associated operations. (4) To introduce trust agreement agency business and associated operations. (5) To introduce salary prepayment service and associated operations. (6) To confirm the authority of a corporate representative or its agent, when the referrer is a corporation. (7) To administer the process of contract execution with referrers related to our services. (8) To exercise rights and fulfill obligations, in accordance with contracts and laws related to our services. (9) To ensure smooth and accurate execution of business with clients, including service-related communication connected with transactions as well as mailings, such as greeting cards. (10) To facilitate the cancellation of transactions and follow-up after a transaction has been cancelled. (11) To pursue research and development on Financial Products and services through market surveys, data analysis and questionnaires. (12) To present and explain Financial Products and services and introduce upcoming seminars organized by the Company through direct mail and other means of contact. (13) To present products and services offered by affiliated companies and other sources. (14) To respond to referrer inquiries and comments. (15) To ensure security of the Company, especially in regard to the use of information systems and access into facilities. (16) To properly execute services outsourced to us in such cases where we are entrusted with all or some personal information processing tasks by another company.
Business partner information	To facilitate mainly communication with business partners, fulfill contracts and request execution of agreements.
Shareholder information	(1) To carry out stock-related procedures. (2) To communicate with shareholders and respond to inquiries. (3) To implement various measures to facilitate the relationship between shareholders and the Company. (4) To manage shareholder, such as creating shareholder data based on prescribed standards under various laws and regulations.
Information on individuals from whom we have received a request for materials or a question (clients, tax accountants, public accountants)	To respond to inquiries and explain our services.
Information on job applicants, including successful hires	(1) To screen individuals for employment and communicate with them. (2) To execute administrative formalities for new hires.
Employee information	To deal with hiring and labor issues, such as matters pertaining to personnel and general affairs.

B. Purpose of Use of Specific Personal Information

Type of Specific Personal Information	Purpose of Use
Specific Personal Information of the executives and employees of our group companies and their dependents	(1) Preparation, submission, etc. of certificates of employment income, retirement income and withholding taxes, declaration of exemption for dependents, declaration of exemption for insurance premium and special exemption for spouses and other registration statements, application, declaration, payment record, report, etc. (collectively “Registration Statements”). (2) Preparation and submission, etc. of Registration Statements related to health insurance and welfare pension insurance. (3) Preparation and submission, etc. of Registration Statements related to the insured in the third grade of the national pension plan. (4) Preparation and submission, etc. of Registration Statements related to employment insurance. (5) For the member of employees’ stock ownership association, preparation and submission, etc. of legally required documents on the association. (6) For the stock option holder, preparation and submission of record of stock option exercise. (7) Operation related to the (1)-(6) above.
Specific Personal Information of individual payees	(1) Preparation and submission, etc. of payment record for remuneration, fee, contract money and prize money. (2) Preparation and submission, etc. of payment record for real estate rentals, etc. (3) Preparation and submission, etc. of payment record of compensation for acquisition of real estate, etc. (4) Preparation and submission, etc. of payment record of brokerage fee for sales or lease of real estate, etc. (5) Operations related to the (1)-(4) above.

3. Termination of Direct-Marketing Materials

We use personal information in our direct-marketing activities, such as direct mail and telemarketing. However, we will refrain from using an individual’s personal information for this purpose, if that person submits a formal request to stop.

4. Procedures for Requesting Disclosure

We will respond to six types of requests: (1) Request for disclosure in regard to the personal information we have about you in our records and records provided by a third party (2) Request for notification of the intended use of personal information that we have (3) Request for correction of personal information that we have, (4) Request for addition of personal information that we have, (5) Requests for deletion of personal information that we have and (6) Request for termination of use or termination of provision to third parties (collectively, (1) to (6) are hereafter referred to as “Request(s) for Disclosure”) by you or your representative in regard to the personal information. The procedures for requesting disclosure are outlined below.

a) Making a Request for Disclosure

A Request(s) for Disclosure must be made by mailing in a request for a form along with the documents required for a request for disclosure. When making the request in (1) above, you can choose either the providing electromagnetic records or delivering documents as the method of disclosure by us. When mailing us your request, please use a delivery-confirmation service, such as delivery-certified mail or simplified registered mail. Please write “Personal Information Request enclosed” on the envelope in red ink. After reviewing your request and documentation, we will mail you the appropriate form(s) for your Request(s) for Disclosure.

b) Submitting documents

To make a request for disclosure or notification of intended use, you must fill in all required fields on the proper request form and mail in the completed form along with one of the following documents that identifies you: driverﾕs license, resident card or health insurance card.

* Blacken out the field showing place of family registry (permanent address).

c) Request for Disclosure, etc. by an authorized agent

If you appoint an agent to request disclosure of personal information on your behalf, the following documents must be enclosed with the application form.

(1) One of the following documents (copy) identifying the person you have named as your authorized agent: driver’s license, resident card or health insurance card. * Blacken out the field showing place of family registry (permanent address).

(2) Power-of-attorney You must stamp the document with your registered seal and attach a seal impression registration certificate for the seal you have used. If your authorized agent is a legal representative, such as a person in parental authority, he/she may submit a document showing your relationship with him/her instead of the power-of-attorney.

d) Service charge on Request for Disclosure, etc.

When we receive the request to disclose personal information and records provided by a third party and notification of the purpose of use of personal information, we will apply a service charge of \1,100 (includes consumption tax). This amount must be paid by bank transfer to our designated account. The applicant is responsible for the cost of the bank transfer. Applicants should bear in mind that we will not be able to execute a request for disclosure or notification if the required fee is not paid in full.

e) Method of reply

When we disclose the request in (1) of Procedures for Requesting Disclosure, in principle, we will disclose it by the method selected by the requester. However, if you choose the method by providing the electromagnetic method and it is difficult for us to disclose it by that method, we will disclose it in writing to the address stated in the invoice of the claimant. In cases other than the above, we will reply in writing to the address of the applicant, as provided on the request form.

5. Safety management measures

We will take the following safety management measures to prevent leakage, loss or damage of personal data.

(a) We will formulate handling rules regarding the handling method, responsible person / person in charge, and their roles / responsibilities at each stage of handling personal data.

(b) We will appoint a person in charge of handling personal data and clarify the employees who handle personal data and the scope of personal data handled by those employees. We establish a system to report and contact the person in charge when we grasp the facts or signs of violating laws and regulations and handling rules.

(c) We will provide regular training to employees regarding points to note regarding the handling of personal data.

(d) In areas where personal data is handled, we will control the entry and exit of employees and restrict the equipment they bring in and will take measures to prevent unauthorized persons from viewing personal data.

(e) We will implement access control to limit the scope of the person in charge and the personal information database handled.

(f) When handling personal data in a foreign country, we will implement safety management measures after understanding the system regarding the protection of personal information in the country concerned.

6. Contact Point for Questions and Complaints

For further information about personal information management at FPG or to ask a question or make a complaint, please contact the Compliance Department by phone or postal mail.