SEPTENI HOLDINGS CO., LTD.
Yuichi Kouno, Representative Director

1. Compliance with Relevant Laws, Regulations and Guidelines

SEPTENI HOLDINGS CO., LTD. (hereinafter, "the Company") handles individual numbers and specific personal information (hereinafter, “Specific Personal Information, Etc.”) in compliance with the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (hereinafter the “My Number Act”) and the Guidelines for the Proper Handling of Specific Personal Information (for Business Operators) as well as the Act on the Protection of Personal Information (hereinafter the “Personal Information Protection Act”) and other guidelines issued by each ministry or agency.

The Company uses Specific Personal Information, Etc. provided for the following purposes.

(1) Specific Personal Information, Etc. of Business Partners
・Preparation of payment records for real estate transactions
・Preparation of payment records for remuneration, fee, contract money and prize money

(2) Specific Personal Information, Etc. of Shareholders
・Preparation of payment records for payment of dividend or surplus

(3) Specific Personal Information, Etc. of Employees, Etc.
Tax affairs
・Preparation of withholding tax slips
・Preparation of declarations concerning tax exemptions for dependents (reassignment), declarations concerning deductions of insurance premiums and special spouse exemptions for salaried workers
(*) Reports of the payment of salaries and special withholding tax slips for retirement income are included in “Preparation of withholding tax slips”

Social insurance
・Notifications, applications and claims concerning health insurance and employees’ pension insurance
・Notifications, applications and claims regarding unemployment insurance and workmen’s compensation insurance

(4) Specific Personal Information, Etc. of Dependent Family Members of Employees, Etc.
Tax affairs
・Preparation of withholding tax slips
・Preparation of declarations concerning tax exemptions for dependents (reassignment), declarations concerning deductions of insurance premiums and special spouse exemptions for salaried workers

Social insurance
・Notifications concerning health insurance and employees’ pension insurance

The Company establishes Rules for the Handling of Individual Numbers and Specific Personal Information and complies with these rules to prevent the leakage, destruction, or damage to Specific Personal Information, Etc.

The Company may outsource the handling of Specific Personal Information, Etc. to a third party. In this case, the Company will exercise the necessary and appropriate oversight of contractors in accordance with the My Number Act and the Personal Information Protection Act.

The Company will endeavor to continuously improve its handling of Specific Personal Information, Etc.

If requested to disclose Specific Personal Information, Etc. by the person it concerns or his or her proxy, the Company will respond without delay, except in the following cases:

• the risk of injury to the life or bodily safety of the person or a third party or the risk of impinging on the rights and interests of the person or a third party or their property exists as a result of such disclosure and delivery;
• such disclosure and delivery would result in a material interference with the Company’s operations; or
• such disclosure and delivery would result in a violation of other laws.

Please direct any inquiries, questions or complaints concerning the disclosure of Specific Personal Information, Etc. to:

Enacted:

January 1, 2016

Revised:

January 1, 2018

This English translation is for reference purposes only and not a legally definitive translation of the original Japanese texts. In the event a difference arises regarding the meaning herein, the original Japanese version shall prevail as the official authoritative version.