We believe the health and safety of our employees are essential to our sustained growth. To promote the health and safety of our employees proactively, we will provide a safe and healthy working environment where all employees can choose healthy work styles.

OUR HEALTH MANAGEMENT SYSTEM

To discuss the following issues, a director and managers of each section hold meetings every month.
・ Report on the current status of employee's health and working hours and,
・ Issues and measures for occupational health and safety and health management, etc.
Appointing several employees as promoting health management from the management department, planning measures to maintain and improve employee's health in cooperation with the health insurance union and employee representatives, etc.

ON GOING HEALTH MANAGEMENT INITIATIVES AND RESULTS

We recognize the following issues as crucial to health management and aim to improve them on a daily basis. These measures contribute to the increased health and safety of our employees as well as to the stable and sustained growth of our company.

1. Reduction of Overtimee
As a result of our continued efforts, the average monthly overtime has been reduced year by year within the range of 45 hours. We will strive to further reduce working hours and thoroughly manage working hours so that all employees will not perform more than 80 hours per month in compliance with the agreement stipulated in Article 36 of the Labor Standards Act.

2. Providing a Healthy Working Environment
To achieve a balance between work and child-rearing and to maximize their abilities, we will set the following goals and take measures:
・ Maintain 100% of female employees take childcare leave.
・ At least 70% of male employees take childcare leave.

3. Raising and Maintaining Health Checkup Rates
We intend to maintain 100% of our general health checkup rate and raise our rates for re-examination, precision checkup, and specific health guidance.

4. Mental Health Care
As a result of our successful reduction of working hours, the stress check test has shown positive effects on several indicators of employee health, including job satisfaction, absenteeism and presenteeism. To further improve mental health, we will work to bring the stress check test rate close to 100%, and promote high-stress employees to provide consultations with industrial physician and/or external consultation services.

5. Understanding the Posture for Health Management of our Business Partners
When purchasing products and services, we will endeavor to gain a grasp on the posture for health management of our business partners, including the following:
1. Status of implementation of health management measures.
2. Status of acquisition of awards for Health and Productivity Management Organization and other recognition programs.
3. Status of overwork of employees.
4. Status of implementation of mental health measures.
5. Status of compliance with laws and regulations related to industrial safety and health.
6. Status of certification related to industrial safety and health.

BayCurrent Consulting, Inc.
Chief Executive Officer Yoshiyuki Abe

To achieve our mission, it is a crucial subject to protect our client's information assets from every threat by holding high corporate morals regarding information security. Therefore, in order to thoroughly protect information assets adequately, we will set a basic information security policy as follows and disseminate this in-house:

INFORMATION SECURITY POLICY GUIDELINES

1. We will take measures to protect information assets from unauthorized access, loss, leakage, and tampering. Security measures will be continuously improved upon in order to adapt to evolving threats.
2. We will perform continuous risk assessment for all relevant information assets, and take appropriate security measures for each risk.
3. We will continuously train and educate its directors, officers, and employees to raise their awareness of information security and maintain their understanding of our information security management system.
4. We will comply with laws, regulations, and standards related to information security.
5. We will comply with all contractual requirements related to information security and confidentiality contained in contracts with our customers.
6. We will strive to prevent the occurrence of information security breaches, and in the case of such a breach, take appropriate measures to prevent repeat occurrences.

Amendment Dates:
Mar 1, 2012
Nov 11, 2018

BayCurrent Consulting, Inc.
Chief Executive Officer Yoshiyuki Abe

BayCurrent Consulting, Inc.’s information security management system is now ISO/IEC 27001:2013 certified.

ACCREDITATION INFORMATION
Certifying Body: BSI Group Japan K.K Certification ID: IS 94222 Standards Applied: ISO/IEC 27001:2013　/　JIS Q 27001:2014 First Certified: 2005/06/23 Last Renewed: 2020/06/11 Certification Area: System development and Internal systems management Certifying Authorities: ISMS Accreditation Center (ISMS-AC)
The ANSI (American National Standards Institute)-ASQ (American Society for Quality) National Accreditation Board (ANAB)

BayCurrent Consulting, Inc. (“the Company”) informs users regarding the purposes and scope of use of personal information in accordance with its Privacy Policy (“this Policy”) as follows.

1. Definitions

Definitions of terms used in this Policy are defined in accordance with the Act on the Protection of Personal Information and related regulations (hereinafter referred to collectively as “laws and regulations”).

2. Collection of Personal Information

(1) When acquiring personal information, the Company shall do so in an appropriate and lawful manner, and only to the extent necessary to achieve the purposes of use announced or notified to users (including announcement on the Company’s website, and the same shall apply hereinafter).

(2) In principle, when acquiring personal information that requires special care and consideration, the Company shall obtain the consent of the person in advance, before acquiring it.

3. Use of Personal Information

The Company shall use personal information for the following or related purposes.

Types of personal information	Purposes of use
Personal information about transaction partners (in the case of corporate customers, their officers and employees)	・To conduct business negotiations and perform contractual obligations, and to engage in other communication necessary for transactions ・To manage information on transaction partners
Personal information about persons who have participated in various seminars, exhibitions and forums, etc., hosted by or involving the Company (hereinafter referred to as “events”)	・To provide information on events and send email newsletters
Personal information acquired from websites, etc., operated by the Company	・To provide information on events and send email newsletters
Personal information about shareholders (in the case of corporate shareholders, their officers and employees)	・To exercise rights and perform obligations under the Companies Act ・To manage shareholders, such as creating records based on various laws and regulations
Personal information about job applicants and those who wish to receive information about the Company’s recruitment activities	・To provide information and engage in communication necessary for the Company’s recruitment activities
Personal information about officers, employees and their families, and retirees	・To engage in business-related communication,determine assignment to projects, introduce to business partners, and perform other business activities ・To pay remuneration (wages, bonuses and allowances, etc.), perform personnel and labor management obligations, and provide benefits ・To carry out health management ・To conduct business relating to shareholders’ associations ・To perform various procedures after retirement
Specific personal information about transaction partners	・To perform clerical work to prepare records of payment for compensation or fees, etc.
Specific personal information about shareholders	・To perform clerical work to prepare records of dividend payouts, etc.
Specific personal information about officers, employees and their families, and retirees	・To perform clerical work to prepare income tax withholding slips, etc. ・To perform clerical work regarding notifications, etc., relating to residents’ tax ・To perform clerical work regarding notifications, etc., relating to health insurance and employees’ pension insurance ・To perform clerical work regarding notifications, etc., relating to employment insurance ・To perform clerical work to prepare records of payment, etc. for employee shareholders’ associations

4. Outsourced Management

When entrusting portions of business processes relating to personal information to external business operators, the Company selects business operators whose level of personal information protection is recognized as sufficient, and clarifies the obligations deemed necessary by contractual agreement, etc.
The Company also requests contractors to handle personal information appropriately, and continuously supervise and audit as necessary to ensure safe management.

5. Joint Use of Personal Information

The Company may make joint use of the personal data it acquires as necessary. Items and scope of joint use are as follows.

• (1) Purposes of use
  Achievement of business objectives of joint users
• (2) Scope of joint users
  BayCurrent Health Insurance Society and Executives and Employee Shareholders’ Association
• (3) Items of personal data
  Names, dates of birth, addresses, telephone numbers, email addresses, department affiliations and job titles (of officers, employees, their families, and retirees), and other data necessary to achieve the business objectives of the joint user
• (4) Party responsible for the management of shared personal data
  BayCurrent Consulting, Inc.

6. Provision of Personal Data to Third Parties

The Company shall not disclose personal data it receives to any third party, except in the following cases.

• (1) When the Company has the individual’s prior consent
• (2) When outsourcing to the extent necessary to achieve the purposes of use
• (3) When providing personal data to person within the scope of joint use as provided
• (4) When required by laws or regulations
• (5) When providing personal data to person within the scope of joint use as provided
• (6) When disclosure is necessary to protect human life, health or property, and it is difficult to obtain the consent of the individual
• (7) When disclosure is particularly necessary for public health purposes or for the sound development of children, and it is difficult to obtain the consent of the individual
• (8) There is a need to cooperate with a central government organization or a local government, or an agent acting on their behalf, performing affairs prescribed by laws and regulations, and there is a possibility that obtaining consent from the Individual could interfere with the performance of the said affairs

7. Security Measures

The Company will prevent unauthorized access to personal information, leakage, falsification, loss, etc., and implement appropriate security measures for personal information.
Specific security measures are stipulated under separate internal regulations. The main content is as follows.

• (1) Systematic Security Measures
• (i)　The Company will appoint a person responsible for handling personal information (“Personal Information Supervisor”) and confirm the state of the handling of personal information by employees as appropriate.
• (ii)  The Personal Information Supervisor will regularly confirm and review the state of handling of personal information.
• (2) Human Security Measures
• (i)　The Company will conduct education and awareness-raising activities for all officers, employees, and related persons to ensure that personal information is handled appropriately, under the leadership of the Personal Information Supervisor.
• (3) Physical Security Measures
• (i)　The Company will take measures to prevent anyone other than the Personal Information Supervisor and the individual in question from easily viewing or otherwise using personal information.
• (ii)  The Company will take necessary measures to prevent theft or loss of equipment, electronic media or documents, etc., that contain or handle personal information in controlled areas and handling areas.
• (iii) When employees carry electronic media or documents containing personal information, etc., the Company will take safe measures to prevent loss or theft, such as setting passwords or transporting such items in an envelope before putting theｍ in a bag.
• (iv) If personal information is deleted or equipment or electronic media, etc., where personal information is recorded is disposed of, the Personal Information Supervisor will confirm this.
• (4) Technological Security Measures
• (i)　In order to prevent unauthorized access to personal information, the Company will clarify the devices that can be used to handle personal information and employees who handle the equipment.
• (ii)  The Company will identify and authenticate employees who use information systems that handle personal information using user control functionality (user account control) on devices that can handle personal information.
• (iii) The Company will take necessary measures to protect information systems from unauthorized access or software from external locations.
• (5) Assessment of External Environment
• (i)　We implement security measures based on an assessment of the privacy legislation in the foreign countries in which we store personal information.

8. Disclosure, Correction, Deletion and Suspension of Use of Personal Data, and Suspension of Provision to Third Parties, etc.,

Please contact the Company via the following inquiry desk for requests regarding personal data held by the Company, including disclosure, correction, deletion, suspension of use, suspension of provision to third parties, and disclosure of records concerning provision of information to third parties, etc.
After confirming the identity of the individual, the Company will respond in accordance with laws and regulations.

9. Use of Cookies

• (1) To enable users to use the Company’s website more conveniently, we use cookies (information sent from the server to the user’s browser and stored on the user’s device (e.g., computer or mobile device) to identify the user on the server side) to collect information about users and send it to the third party.
• (2) From your browser settings relating to sending and receiving cookies, you can select options such as “Allow cookies,” “Reject cookies,” or “Notify when cookies are received.” If you choose to opt out of using cookies, you may not be able to receive some services provided by the company.

10. Compliance with Laws and Regulations

The Company complies with laws, regulations, guidelines, and other norms relating to the protection of personal information.

11. Contact for Inquiries

For questions and inquiries about personal information, please contact the Company at the following address:

Information Systems Department
BayCurrent Consulting, Inc.

Address: Azabudai Hills Mori JP Tower, 3-1, Azabudai 1-Chome, Minato-ku, Tokyo 106-0041 Japan

MAIL: info_security@baycurrent.co.jp

Revised on March 1, 2012
Revised on February 1, 2019
Revised on December 12, 2020
Revised on April 1, 2022
Revised on June 16, 2023
Revised on January 4, 2024

BayCurrent Consulting, Inc.
Yoshiyuki Abe, Chief Executive Officer

BayCurrent Consulting Co., as a corporation with social responsibilities, hereby establishes and observes the following basic policy in order to prevent damage caused by “anti—social” groups or individuals (including Boryoku-dan) ("Anti-Social Forces").

1. We will have absolutely no dealings with Anti-Social Forces.
2. We will strengthen our cooperation with external specialists such as police and attorneys, to be prepared to deal with unjustified demands from Anti-Social Forces.
3. We will never provide any funding to or engage in any transactions with Anti-Social Forces.
4. We will take measures against unjustified demands from Anti-Social Forces through the commitment of our corporation as a whole, and make efforts to ensure the safety of corporate officers and employees who deal with unjustified demands.
5. We will take measures against unjustified demands from Anti-Social Forces with absolute fortitude, such as by taking civil and criminal legal actions in response to such demands.

BayCurrent Consulting, Inc. CEO Yoshiyuki Abe

The official website (hereinafter referred to as the "Website") of BayCurrent Consulting, Inc. (the "Company") was built for the purpose of providing information on the Company. By using the Website, you agree to the following terms of use.
The Website, as well as links leading from it, may be subject to terms of use, etc. other than those described here. In such cases, please use the links in accordance with the applicable terms and conditions.

1. Disclaimer

All content (the "Content") provided by the Company on the Website is for informational purposes only. The Company provides no warranty and bears no responsibility regarding the completeness, accuracy, timeliness, validity, immediacy, reliability, appropriateness, usefulness, marketability, or non-infringement of intellectual property rights of any information provided through the Content (the "Information Provided").
Users of the Content bear all responsibility for determining whether or not to trust the Information Provided through said Content, whether or not to conduct transactions, and so on. The Company shall not be held responsible for the outcome of any investment, sale, loan, or any other transaction or business conducted by the user using or referring to the Information Provided.
In addition, any complaints, claims, or disputes regarding content, etc., provided by third parties shall be resolved between the user and the third party, without any involvement of the Company.
The Company may update, add, change, or delete all or part of the Content, or it may suspend or end its provision of the Content at its sole discretion without prior notice to the user. In addition, the Company will not be held responsible in the event that the user experiences delays in obtaining information, loss or corruption of information, or other kinds of damage.

2. Possession of Intellectual Property Rights, Etc.

All copyrights, trademarks, designs rights, patent rights, and other intellectual property rights relating to the Content are the property of the Company or expressly stated third party.
The user may not copy, reproduce, sell, or conduct any other kind of secondary use of the Content for any commercial or non-commercial purpose without the prior consent of the Company.
In the event that the user uses the Content under Article 30 of the Copyright Act, "Reproduction for Private Use," Article 32, "Quotation," etc., the user shall cite the Company's name as the source.

3. Links

You are free to link to any page on the Website. However, we refuse links from sites that we deem to be illegal or obscene, or go against public order and morals, and any links to the Website through unclear methods.
Also, please be aware that the URL of the Website may change without notice.
Any complaints, claims, or disputes arising from the link shall be resolved at the sole responsibility and expense of the user who created the link, and the Company shall not bear any responsibility.

4. Damages

In the event that a user violates these terms of use and causes harm to the Company, the Company may demand any immediate damages from the user (including, but not limited to, attorneys' fees, investigation costs, expert appraisal costs, and legal fees).

５．Changes to Terms of Use

The Company may modify these terms of use without the prior consent of the user. The Company may notify the user on the Website or through another method that the Company deems appropriate. In such an event, the revised terms of use shall become effective as soon as they are posted or displayed on the Website. When using the Website, please refer to the latest terms of use posted on the Website.

６．Governing Law and Jurisdiction

The interpretation and application of the Website and these terms of use shall be governed by the laws of Japan.
In addition, the Tokyo District Court shall have exclusive jurisdiction in the first instance over any dispute concerning the Website.

April 1, 2022
BayCurrent Consulting, Inc.

The official social media accounts (hereinafter referred to as the "Accounts") of BayCurrent Consulting, Inc. (the "Company," and the pages created in accordance with the Company's Accounts are the "Company's Account Pages") are designed for the purpose of providing information on the Company. By using the Company's Account Pages, you agree to the following terms of use.
The Company's Account Pages may be subject to terms of use, etc. other than the one described here. In such cases, please use the links in accordance with the applicable terms and conditions.

1. Disclaimer

All of the content (the "Content") provided by the Company from its Accounts is for informational purposes only. The Company provides no warranty and bears no responsibility regarding the completeness, accuracy, timeliness, validity, immediacy, reliability, appropriateness, usefulness, marketability, or non-infringement of intellectual property rights of any information provided through the Content (the "Information Provided").
Users of the Content bear all responsibility for determining whether or not to trust the Information Provided through said Content, whether or not to conduct transactions, and so on. The Company shall not be held responsible for the outcome of any investment, sale, loan, or any other transaction or business conducted by the user using or referring to the Information Provided.
In addition, any complaints, claims, or disputes regarding content, etc., provided by third parties shall be resolved between the user and the third party, without any involvement of the Company.
The Company may update, add, change, or delete all or part of the Content, or it may suspend or end its provision of the Content or the operation of the Company's Accounts at its sole discretion without prior notice to the user. In addition, the Company will not be held responsible in the event that the user experience delays in obtaining information, loss or corruption of information, or other kinds of damage.
If the Company deems that the user has violated or is likely to violate the prohibitions set forth in Article 2, the Company may delete any content or comments posted by the user on the Company's Account Pages without any prior notice, block the user from accessing and posting to the Company's Accounts, or take other necessary actions. In addition, the Company shall not be held responsible for any damage to users caused by such measures.
The Information Provided does not necessarily represent any official announcements or opinions of the Company. In addition, the content posted by users on the Company's Account Pages does not reflect the opinions or thoughts of the Company, its employees, or any other party involved with the Company.
The user gives the Company consent to access the user's account and information that the user has made public, including the user's name, profile information, profile picture, gender, network, ID, and friend list.
The Company does not guarantee that it will respond to posts on the Company's Account Pages.

２．Prohibited Acts

The user is prohibited from the following acts (including posting URLs to links containing the following actions or expressions) when using the Company's Account Pages. "Using the Company's Account Pages" means viewing, posting content and comments to, sharing content with, or sending direct messages, etc. to the Company's Accounts.

• (1) Impersonating a third party including the Company
• (2) Using the Company's Account Pages using a third party's identity
• (3) Accessing the Company's Account Pages by unauthorized means
• (4) Copying, reproducing, selling, or conducting any other kind of secondary use of the Content for any commercial or non-profit purpose without the prior consent of the Company
• (5) Political, election-related, or religious activities
• (6) Acts with the objective of meeting strangers
• (7) Posting or sending harmful computer programs, etc. or hacking into computers by borrowing names and addresses of third parties
• (8) Acts that interfere with the operation of the Company's Account or cause loss to the Company and other third parties, or any acts that are likely to do so
• (9) Infringing upon rights of the Company (including its executives and employees) or third parties, including intellectual property rights, right to freedom from defamation, and portrait rights
• (10) Spamming or making duplicated or repetitive posts
• (11) Acts that interfere with the use of or access to the Company's services by other users, whether in its entirety or partially
• (12) Linking that inaccurately represents the Company's Account Pages, such as framing
• (13) Linking from sites that the Company deems to violate laws or public order and morals
• (14) Acts that violate the terms of use set forth by the platform on which the Company's Account is operated
• (15) Acts that fall under any of the following expressions (similar types of expressions are included):

• (i) Expressions that incite criminal activity or acts for criminal purposes
• (ii) Expressions that encourage, suggest, or promote child abuse, violence, or illegal activity
• (iii) Inappropriate content, including child pornography and obscenity
• (iv) Expressions that induce the use of dating sites, casino sites, or the adult entertainment industry
• (v) Expressions that solicit or induce sexual relationships or sexual activity
• (vi) Expressions that adversely affect the sound development of young people
• (vii) Expressions that contain slander against one or more individuals, businesses (including the Company), properties, regions, nationalities, races, ethnicities, religions, etc.
• (viii) Expressions not based on fact that cause misidentification of the Company or other party being in a partnership or cooperation, or those that cause misidentification of the Company or other party being aware, endorsing, supporting, or recommending a linked site
• (ix) Discriminatory expressions
• (x) Expressions that are ethically problematic
• (xi) Misinformation, misrepresentation, and misleading expressions
• (xii) Assertive or conclusive expressions, e.g., "Don't buy this," "absolutely must be stopped," or "worst."
• (xiii) Disclosing information that makes it easy to identify and contact the user or a third party, such as contact information
• (xiv) Expressions that disclose private messages with the Company (including executives and employees) or with a third party
• (xv) Expressions that contain matters regarding the privacy of the Company (including executives and employees) or a third party
• (xvi) Expressions that identify, disclose, or leak personal information of the Company (including executives and employees) or a third party without the consent of the individual or party involved
• (xvii) Content that overloads the Company Account Pages' servers
• (xviii) Expressions that go against the objectives of the Company's Accounts
• (xix) Expressions that contain commercial content for the purpose of advertising, publicity, affiliates, or solicitation
• (xx) Other expressions that the Company deems to be likely to disturb the order of the Company's Accounts

• (16) Other acts that violate or are likely to violate laws or public order and morals, and other acts that the Company deems inappropriate

３．Possession of Intellectual Property Rights, Etc.

All copyrights, trademarks, designs rights, patent rights, and other intellectual property rights relating to the Content are the property of the Company or an expressly stated third party.
The user may not copy, reproduce, sell, or conduct any other kind of secondary use of the Content for any commercial or non-commercial purpose without the prior consent of the Company.
In the event that the user uses the Content under Article 30 of the Copyright Act, "Reproduction for Private Use," Article 32, "Quotation," etc., the user shall cite the Company's name as the source.
If the user posts content to the Company's Accounts, by posting such content, they grant the Company a worldwide, royalty-free, non-exclusive license to use the content (including processing, excerpting, reproducing, publishing, and translating), and agree not to exercise any copyright or other intellectual property rights that may apply to such content against the Company.

４．Damages

In the event that a user violates these terms of use and causes harm to the Company, the Company may demand any immediate damages from the user (including, but not limited to, attorneys' fees, investigation costs, expert appraisal costs, and legal fees).

5. Changes to Terms of Use

The Company may modify these terms of use without the prior consent of the user. The Company may notify the user on the Company's Account Pages or through another method that the Company deems appropriate. In such an event, the revised terms of use shall become effective as soon as they are posted or displayed on the Company's Website. When using the Company's Account Pages, please refer to the latest terms of use posted on the Company's Website.

6. Governing Law and Jurisdiction

The interpretation and application of these terms of use shall be governed by the laws of Japan.
In addition, the Tokyo District Court shall have exclusive jurisdiction in the first instance over any dispute concerning the Company's Accounts.

April 1, 2022
BayCurrent Consulting, Inc.