Personal Information Protection Policy

➊ Personal Information We Collect

The Company may collect the following personal information in connection with the purchase of our products and services, inquiries, requests for materials, consultations regarding research and development, job applications, shareholder and investor relations activities, sustainability-related communications, and other interactions:

Affiliation (company name, organization name, school name), department, and job title

Name, gender, date of birth, and educational background

Address, telephone number, and email address

Details of inquiries, consultations, and application information

Other information provided in connection with the above

➋ Security Measures for Personal Information

The Company’s directors, officers, and employees shall not improperly disclose to any third party or use for unauthorized purposes any personal information obtained in the course of their duties. This obligation shall continue even after they leave the Company.

The Company strictly manages personal information and other internal information through designated Personal Information Management Officers in each department and in compliance with the APPI and other applicable laws and regulations. Specifically:

• The Ethics Committee continuously works to improve the implementation and operation of the Company’s personal information protection program.
• The Company has established the “Basic Compliance Policy” to provide concrete guidance on expected employee behavior.
• The Company conducts planned education and training programs to ensure employees understand and properly manage personal information.
• The Company periodically reviews and evaluates compliance with this Policy, the Personal Information Protection Policy, and internal regulations relating to personal information management, and revises management measures as appropriate to ensure proper information management.

For details regarding other security measures implemented by the Company, please contact the inquiry desk described in Section 7.

➌ Purposes of Use of Personal Information

The Company uses acquired personal information for the following purposes:

1. ① Responding to inquiries regarding products and services, marketing activities, sending materials, communications, and identity verification
2. ② Responding to consultations and proposals relating to research and development
3. ③ Investor relations (IR) and shareholder communications, including responding to inquiries, providing notifications, and fulfilling legal obligations
4. ④ Recruitment activities, including communications with applicants, candidate screening, applicant management, and procedures following hiring decisions
5. ⑤ Responding to opinions and requests relating to sustainability matters
6. ⑥ Providing and delivering SDS reference information and responding to related inquiries
7. ⑦ Maintaining internal records associated with the foregoing purposes, including quality improvement, inquiry history management, and audit support
8. ⑧ Preventing misconduct, ensuring security, and maintaining and improving systems
9. ⑨ Exercising rights or fulfilling obligations under laws or contracts, and handling disputes

Personal information shall be handled only by authorized personnel within the scope of the relevant purpose of use and only to the extent necessary for business operations.

The Company will not use personal information for purposes other than those stated above, except in the following cases:

• Where the individual’s consent has been obtained
• Where the information is used in a form that does not identify the individual (e.g., statistical data)
• Where use for other purposes is permitted under applicable laws and regulations

➍ Joint Use and Provision of Personal Information to Third Parties

(1) Joint Use of Personal Information

The Company may jointly use personal information as follows:

1. a. Items of Personal Information Subject to Joint Use
   The information listed in Section 1, “Personal Information We Collect.”
2. b. Scope of Joint Users
   The Company and its domestic and overseas affiliated companies (see the Company’s list of affiliated companies):
   https://www.nippon-chem.co.jp/en/company/concerned.

3. c. Purposes of Joint Use
   The purposes described in Section 3, “Purposes of Use of Personal Information.”
4. d. Party Responsible for the Management of Jointly Used Personal Information
   Nippon Chemical Industrial Co., Ltd.
   11-1, Kameido 9-chome, Koto-ku, Tokyo 136-8515, Japan
   Yota Tanahashi, Representative Director and President

(2) Joint Use with Overseas Affiliates

Where the Company jointly uses personal data with affiliated companies located outside Japan pursuant to the preceding paragraph, the Company shall take the measures necessary to ensure that such affiliated companies continuously implement safeguards equivalent to those required of personal information handling business operators under the APPI.

For details regarding these measures, please contact the inquiry desk described in Section 7.

(3) Provision to Third Parties

The Company will not provide customers’ personal information to third parties except in the following cases:

• Where the customer’s consent has been obtained
• Where the information is disclosed in a form that does not identify the customer (e.g., statistical data)
• Where disclosure is made to service providers bound by confidentiality obligations and only to the extent necessary to achieve the relevant purpose of use
• Where, based on the contents of an inquiry or request for materials, it is reasonably determined that a response from an authorized distributor or other business partner would be appropriate, and disclosure is made to such distributor or partner
• Where all or part of the Company’s business is succeeded by another entity
• Where disclosure is permitted under applicable laws and regulations
• Where disclosure or submission is required by a judicial or administrative authority pursuant to law
• Where the disclosure falls within the scope of the joint use described above

➎ Outsourcing of Personal Information Handling

When disclosing personal information to a third party for the purpose of outsourcing business operations, the Company shall evaluate such third party in accordance with predetermined standards, enter into the necessary agreements, and take all other measures required by applicable laws and regulations.

➏ Requests for Disclosure and Other Rights

If a customer, or a representative whom the Company reasonably determines to be duly authorized by the customer, requests disclosure or other actions concerning the customer’s personal information, including: Notification of the purpose of use
Disclosure of personal information or records of third-party provision
Correction, addition, or deletion of personal information
Suspension of use or suspension of provision to third partiesthe Company will respond in accordance with the APPI.
For such requests, please contact the inquiry desk described in Section 7.

➐ Contact Information

For opinions, questions, complaints, requests, or any other inquiries regarding the handling of personal information, please contact:

[Department in Charge]
General Affairs & Human Resources Department
Nippon Chemical Industrial Co., Ltd.
11-1, Kameido 9-chome, Koto-ku, Tokyo 136-8515, Japan
Tel: +81-3-3636-8111
E-mail: info-privacy@nippon-chem.co.jp