MISUMI Group Inc.

Privacy Policy for Shareholders

This Privacy Policy (“Policy”) sets out how MISUMI Group, Inc. (“MISUMI”) handles the personal information of shareholders used for its business.
MISUMI will appropriately handle the personal information of shareholders by observing MISUMI Group Fundamental Privacy Policy, this Policy, laws, and regulations related to the protection of personal information, and any other applicable standards.

Article 1 Definition

Article 1 Definition

Terms in this Privacy policy shall be defined as follows. The terms not defined in this Policy shall be defined in accordance with applicable the laws and regulations related to protection of personal information.

(1)

Shareholder shall mean a person, a company or any organization who owns shares of MISUMI.

(2)

Personal Information shall mean information relating to a living individual and that either contains a name, date of birth, or other personal descriptions which identify a specific individual (including those which can be readily collated with other information and thereby identify a specific individual), or contains an individual identification code

(3)

Principal means the person who is identified by such personal information.

Article 2 Shareholders’ Personal Information that MISUMI Acquires

Article 2 Shareholders’ Personal Information that MISUMI Acquires

MISUMI may acquire the following personal information of Shareholders.

(1)

Names, the names of company or organization representatives if the shareholder is a company or organization, address, number of shares, the date of acquisition of shares, phone numbers, email address, and similar types of information.

(2)

Contents of communications between shareholder and MISUMI such as conversations, written communications, telephone calls, emails, interviews, etc.

Article 3 Purpose of Use

Article 3 Purpose of Use

1.

Personal information that MISUMI acquires shall be used for the following purposes. MISUMI will not use the personal information for any purpose other than the following without the principal’s consent.

(1)

To exercise shareholders’ rights or pursue the obligations based on the Company Act.

(2)

To provide information to shareholders regarding business operations of MISUMI and its affiliates and subsidiaries.

(3)

To take actions to improve the relationship between shareholders and MISUMI

(4)

To provide payments such as dividends or information about the status of the same to shareholders.

(5)

To manage shareholders, such as by aggregating or reviewing shareholders data based applicable laws and regulations, statistics, or in any other way.

(6)

To respond to the inquiry from shareholders

2.

MISUMI will not, in case of altering a utilization purpose, do so beyond the scope recognized to be reasonably relevant to the pre-altered utilization purpose. Any alterations will be publicized on MISUMI’s website.

Article 4 Disclosure to Third Party

Article 4 Disclosure to Third Party

MISUMI will not provide personal data to a third party without first obtaining the principal's consent, except in the following cases;

(1)

where personal information is provided for the purposes set in Article 3, provided that MISUMI will enter non-disclosure agreements imposing the entrusted parties not to use the personal information for any purpose other than the entrusted matter

(2)

where permitted as an exception under applicable laws and regulations

(3)

where consented by the shareholder

(4)

where necessary under applicable laws and regulations

Article 5 Disclosure, Correction, and Suspension etc.

Article 5 Disclosure, Correction, and Suspension etc.

MISUMI will respond quickly and in good faith, when requested by a shareholder, to notify the shareholder of the purpose of use, disclose, revise, delete, or suspend use of the retained personal data, suspend the provision to third parties, or disclose the record on provision to third parties. Please contact the following contact. We may ask for a fee to notify the shareholder of the purpose of use and to disclose retained personal data (including to disclose the record of provision to third parties.)

<Contact>

<Contact>

Corporate Relations Department, IR/SR Team, MISUMI Group Inc.

Article 6 Matters relating to the Retained Personal Data

Article 6 Matters relating to the Retained Personal Data

1.

Information "Personal Information Handling Business Operator”
MISUMI Group Inc.
KUDAN-KAIKAN TERRACE 6-5,Kudanminami 1-Chome, Chiyoda-ku, Tokyo, 102-8583, Japan
Representative Director and Chairman Kosuke Nishimoto

2.

Security Control Action
MISUMI takes necessary and appropriate security control actions, in order to manage personal information to protect from leakage, loss, damaging etc. The security control actions MISUMI takes are as below.

Organizational Security Control
MISUMI sets internal rules, such as Information Security Basic Policy, Information Security Guidelines, and Rules for Handling Personal Information, and handles personal information according to these internal rules. MISUMI also appoints a person in charge on handling of personal information, conducts periodical investigation on what personal information is being collected, and establishes systems to respond to a leakage accident if it happens.

Human Security Control
MISUMI has its employees periodically to take information security training including how to handle personal information so the personal information is handled appropriately. When personal information is provided to entrusted parties or joint users as set forth in Article 4, MISUMI manage and supervises such entrusted parties or joint users so as the personal information is handled appropriately.

Physical Security Control
MISUMI uses security cards for entry to its offices where personal information is stored, and implements other security control actions to protect the information from being stolen or lost such as locking devices and encrypting electronic mediums. In the case a device or electronic media is stolen or lost, MISUMI sets some measures such as encryption or password protection to prevent personal information from being easily accessible. Additionally, when personal data is to be deleted, or devices or electronic medium including personal data are to be discarded, MISUMI uses measures to ensure that personal information is not recoverable from the deleted or discarded medium.

Technical Security Control
For databases which include personal information, MISUMI sets access control by limiting access rights so the employees who can access such information is limited. Also, MISUMI identifies and tracks those who access such systems. Additionally, MISUMI uses its security controls to protect the systems that handle personal information to prevent unauthorized access, illegal software, or information leakage.

Understanding of Surrounding of other countries.
When MISUMI handles personal information in other countries, MISUMI understands the personal protection system of such country and takes security control measures to comply with legal requirements.

April 1, 2022

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