Regarding the Privacy Policy in the UACJ Group

1. Compliance with Related Legislation and Guidelines

With regard to the handling of personal information and personal data stipulated in the Act on the Protection of Personal Information (hereinafter, “Personal Information Protection Act”) (hereinafter, “Personal Information, etc.”), UACJ Corporation (hereinafter, the “Company”) or its subsidiaries^*1 in Japan comply with the Act on the Protection of Personal Information, other laws and ordinances, [the Guidelines on the Act on the Protection of Personal Information], and other norms.

2．Handling of Personal Information, etc.

The Company or its subsidiaries in Japan will use Personal Information, etc., within the scope of the purpose communicated to the person in question in advance or stated in the “Handling of Personal Information, etc., in the UACJ Group.” In addition, the Company or its subsidiaries in Japan will take appropriate responses as stipulated in the procedures of the “Handling of Personal Information, etc., in the UACJ Group” if the person in question requests disclosure of their personal data.

3. Items Related to Safe Management Measures

The Company or its subsidiaries in Japan have established and comply with “Personal Information Handling Regulations” to prevent leaks, losses or damage of Personal Information, etc., and to appropriately manage other personal information, etc., in other ways. In addition, they conduct necessary and appropriate supervision of their employees and outsourcing partners who handle personal data.

4. Representative Inquiry Counter

For any inquiries with regard to the handling of personal information, etc., at the Company or its subsidiaries in Japan, contact the following representative counter.

UACJ Group Personal Information Consulting Counter, General Affairs Department, UACJ Corporation
Tokyo Sankei Bldg., 1-7-2, Otemachi, Chiyoda-ku, Tokyo 100-0004, Japan

April, 2024

• *1 Subsidiaries of the Company in Japan (as of April 1, 2024) are the following 20 companies:
  UACJ Nagoya Alupack Corporation, Sansen Co., Ltd., UACJ Fukaya Service Corporation, UACJ Trading Corporation, Izumi Metal Corporation, KAMAKURA INDUSTRY COMPANY LIMITED, NAKS Corporation, UACJ Aluminum Center Corporation, UACJ Marketing & Processing Corporation, UACJ Extrusion Corporation, UACJ Extrusion Nagoya Corporation, UACJ Extrusion Oyama Corporation, UACJ Extrusion Gunma Corporation, UACJ Extrusion Shiga Corporation, UACJ Foil Corporation, Nikkin Co., Ltd., UACJ Foil Service Corporation, UACJ Foundry & Forging Corporation, UACJ Metal Components Corporation, and UACJ Green-net Corporation

Regarding the Handling of Personal Information, etc. in the UACJ Group

1. Personal Information Received or Retained and Purposes of Use

UACJ Corporation (hereinafter the “Company”) and each of its subsidiaries in Japan *1 will use any of the following personal information they receive or retain for the following purposes only, and will not use such for any other purposes:

(1) Personal Information of Customers and Business Partners (including those who have exchanged business cards with any employees of the Company or its subsidiaries in Japan)

• Notification of various types of services;
• Fulfillment of various types of contracts;
• Provision and introduction of products and services;
• Surveys and analysis on product development and service improvements such as usage conditions of products and services and satisfaction surveys;
• Notification of events, campaigns and exhibits; and
• Responses to various types of inquiries

(2) Personal Information of Shareholders

• Exercise of rights and fulfillment of obligations under the laws and ordinances;
• Implementation of various types of measures (including questionnaires) for shareholders; and
• Management of shareholders (including preparation of shareholders data) under the laws and ordinances

(3) Personal Information of Applicants and Participants in Events, Factory Tours, Work Experience Programs

• Smooth operation of events;
• Notifications and Announcements; and
• Use of photos, video and audio shot at any of the events, factory tours and work experience programs in public relations and advertisements of the Company or its subsidiaries in Japan (posting them in newspapers, magazines, pamphlets, and on posters and webpages)

(4) Personal Information of Any of the Individuals Who Make Inquiries, Comments or Requests for Materials

• Responses to inquiries and comments;
• Surveys or confirmation required for responding to inquiries and comments;
• Sending of materials; and
• Contacts and follow-up after sending materials

(5) Personal information of Job Applicants (including those who have registered at “Recruitment Information” on the Company’s Website)

• Provision and notification of recruitment information to job applicants; and
• Employment service management

(6) Personal Information of Officers, Employees, Family Members of Officers and Employees

• Procedures related to business communication, payment of wages, and social insurances, procedures for making applications and registrations required in business, including the preparation of various lists of names, provision of employee benefits, and acquisition of qualifications, and legally required procedures;
• Grasping of work performance, determination, deduction and payment of wages, payment of congratulatory and/or condolence money, tax payment procedures such as tax withholding at the source, grasping of reason for taking leave, provision of employee benefits, employment management, emergency contact, union fees deduction administrative work, and various procedures required under the laws;
• Housing loan procedures;
• Personnel performance evaluation, determination of assignment and transfer, preparation of notification of transfers, organization lists, and telephone directories, implementation of reward and punishment, procedures for retirement or resignation, and employee history management;
• Appropriate health management and employment management; and
• Other employment management

(7) Personal Information of Retired or Resigned Employees

• Execution and Notification of Obligations under Labor-Related Laws and Ordinances; and
• Notification Related to the Association of Former Employees

Note that the Company and each of its subsidiaries in Japan may outsource the handling of personal data in whole or in part to third parties within the scope required for the achievement of the above Purposes of Use. In such cases, the Company and each of its subsidiaries in Japan conduct necessary and appropriate supervision of the applicable third party to ensure safe management of outsourced personal data, for example, by entering into an agreement regarding the handling of personal data with the applicable outsourcing party.

2. Disclosure and Provision of Personal Data to a Third Party.

Without prior approval from the person in question, neither the Company nor each of its subsidiaries in Japan will disclose or provide personal data to a third party, except in the following instances:

• (1) When it is in accordance with legal requirements;
• (2) If there is a likelihood of endangering the life, body or property of a person, and when it is difficult to obtain approval from the person in question;
• (3) When it is particularly necessary to improve public health or to promote the sound growth of children, and when it is difficult to obtain approval from the person in question; and
• (4) When it is necessary to cooperate with a national agency, local government or other entity outsourced by such to execute administrative operations stipulated by laws and ordinances and if receiving the approval from the person in question may obstruct the execution of said administrative operations

3. Joint Use of Personal Data

The Company and its subsidiaries in Japan will jointly use personal data retained by them as described below; provided, however, that aside from this, when prior notification has been made individually to the person in question, personal data of the applicable person may be jointly used in accordance with the details of the applicable notification.

• (1) Items of Personal Data to be Jointly Used
  Name, address, phone number, fax number, e-mail address
• (2) The Range of Entities Who Jointly Use
  The Company and its subsidiaries in Japan
• (3) Purposes of Use by Entities Who Jointly Use
  Purposes of use stipulated in the above Item 1.
• (4) The Entity with Responsibility for the Management of Personal Information to be Jointly Used
  UACJ Corporation

4. How to Request Notification of Purposes of Use of Retained Personal Data or for Disclosure, Correction, Deletion or Suspension of Use

Regarding disclosure, correction, deletion and suspension of use of retained personal data, please request a company that retains the applicable personal data among the Company and each of its subsidiaries in Japan.
When the applicable company is unknown, make an inquiry to the Representative Counter stated in “Item 4 of “Regarding the Privacy Policy in the UACJ Group”.

5．Complaints Regarding the Handling of Personal Data Retained

Please address the written inquiry to the Representative Counter stated in Item 4 of the “Regarding the Privacy Policy in the UACJ Group.”

• *1 Subsidiaries of the Company in Japan (as of April 1, 2024) are the following 20 companies:
  UACJ Nagoya Alupack Corporation, Sansen Co., Ltd., UACJ Fukaya Service Corporation, UACJ Trading Corporation, Izumi Metal Corporation, KAMAKURA INDUSTRY COMPANY LIMITED, NAKS Corporation, UACJ Aluminum Center Corporation, UACJ Marketing & Processing Corporation, UACJ Extrusion Corporation, UACJ Extrusion Nagoya Corporation, UACJ Extrusion Oyama Corporation, UACJ Extrusion Gunma Corporation, UACJ Extrusion Shiga Corporation, UACJ Foil Corporation, Nikkin Co., Ltd., UACJ Foil Service Corporation, UACJ Foundry & Forging Corporation, UACJ Metal Components Corporation, and UACJ Green-net Corporation