1．Basic Policy

TESS Holdings Co., Ltd. (the “Company”) believes that a corporation has an important social obligation to handle Personal Information (defined in Paragraph 2) appropriately in compliance with the Act on the Protection of Personal Information.
The Company has established the following Privacy Policy (the “Policy”) to ensure appropriate handling and management of Personal Information.

2．Definition of Personal Information

For the purposes of this Policy, Personal Information refers to information related to a living individual that falls under any of the below:

• (1) Information which allows identification of a specific individual by the included name, birth date, and other descriptions (including information that could easily be reconciled with other information to identify a specific person); and
• (2) Information that includes Individual Identification Code.

3．Acquisition and Use of Personal Information

When acquiring Personal Information, the Company will disclose or notify its purpose of use (through this Policy or otherwise) and employ lawful and fair means of acquisition. No Personal Information will be acquired by the Company unless permitted by the person to which the information relates, or by deception or other wrongful means. The Company will use Personal Information appropriately and to the extent necessary for achieving its purpose of use.

4．Purposes of Use of Personal Information

The Company will use and keep Personal Information for the following purposes. No Personal Information will be used or provided by the Company for any other purposes than those listed below without prior consent of the person to which the information relates.

(Personal Information of customers)

• ・To provide information about our group.
• ・To maintain, manage, protect and improve the services and solutions provided by the Company and develop additional services and solutions (such as offering new rate plans or new systems in our electricity retail business.)
• ・To respond to inquiries of customers.
• ・To conduct any other activities related to the foregoing or otherwise achieve the purposes of use specified at the time of acquiring Personal Information.

(Personal Information of business partners)

• ・For communication necessary in business, performance of agreement or duties (e.g. safety and health control at a construction site), business negotiation, etc.
• ・To provide information to and communicate with business partners.
• ・To manage information about business partners.
• ・To conduct any other activities related to the foregoing or otherwise achieve the purposes of use specified at the time of acquiring Personal Information.

(Personal Information of shareholders)

• ・To manage our shareholders and stocks.
• ・For the exercise of rights or performance of obligations by shareholders or the Company.
• ・To create documents, records, or data required under laws and regulations.
• ・To conduct any other activities related to the foregoing or otherwise achieve the purposes of use specified at the time of acquiring Personal Information.

(Personal Information of employees, officers and other members of our group)

• ・For business communication.
• ・For the payment of compensation (salary, bonus, allowances and other benefits), performance of HR and labor management, and provision of welfare benefits.
• ・To perform safety and health control for our group members.
• ・To manage HR affairs for our group members.
• ・To conduct any other activities related to the foregoing or otherwise achieve the purposes of use specified at the time of acquiring Personal Information.

(Personal Information concerning applicants for job offers)

Our recruitment and selection activities are conducted through the "TESS Group Joint Recruitment Entity." If you would like to know how we handle the applicants' personal information, please read the Privacy Policy of the above entity.

5．No Disclosure or Providing of Personal Information to Third Parties

Except as provided in the preceding section or unless required by law or regulation, the Company will not disclose Personal Information to any third parties.

6．Management of Personal Information

The Company will take the security measures listed below against any risk of unauthorized access to, or loss, destruction, falsification, leakage, etc., of Personal Information. In addition, the Personal Information held by the Company will be kept accurate and up to date to the extent necessary to achieve their purposes of use and deleted without delay when such use is not necessary anymore.

(Formulation of basic policy)

Establishing a basic policy (that is, this Policy) under which the proper handling of Personal Information or personal data shall be ensured, and measures prescribed by laws, regulations, or guidelines shall be taken.

(Development of disciplines on the handling of personal data)

Establishing the "Basic Rules on the Protection of Personal Information" specifying the conditions under which acquisition, use, saving, providing, deletion, or disposal of Personal Information shall be conducted and the persons responsible for these actions and their respective roles.

(Organizational Security Control Measures)

Appointing persons responsible, specifying employees authorized to handle Personal Information and scope of Personal Information handled, developing a reporting system to be used when any fact or sign of breach is detected, and conducting regular internal audits and other controls on the handling status of Personal Information.

(Human Security Control Measures)

Organizing regular employee training on the points to note about the handling of Personal Information and setting out non-disclosure provisions in our Work Rules.

(Physical Security Control Measures)

Measures against any access to personal data by a person who is not authorized to do so and measures to prevent any theft or loss of device, electronic media, document, etc.

(Technical Security Control Measures)

Conducting access control by limiting persons in charge of handling Personal Information and scope of Personal Information database handled and structuring the protection of information system against any unauthorized access from outside or illicit software.

7．Handling of Non-personally Identifiable Information and Anonymized Information

When creating or using non-personally identifiable information or anonymized information, the Company will establish necessary processing standards and take security control measures in compliance with the Act on the Protection of Personal Information and other applicable laws and regulations and use such Personal Information within its purpose of use.

8．Consignment of Personal Information

The Company may consign or provide acquisition or management of Personal Information to a third party within the scope of use of Personal Information. In such a case, the Company will manage that the party to whom the Personal Information is consigned or provided will satisfy sufficient level of protection of Personal Information.

9．Shared Use

The Company may share the use of Personal Information it acquires under the following conditions:

• 1) Type of Personal Information subject to shared use:
  All Personal Information held by the Company, unless otherwise requested by the person to whom the information relates.
• 2) Scope of co-users:
  ・TESS Engineering Co., Ltd.
  ・Kyoritsu Engineering Co., Ltd.
  ・Kumamoto Nishiki Green Power LLC
  ・Any other companies of our group
• 3) Purposes of use by co-users:
  The same as those provided in Section 4 (Purposes of Use of Personal Information)
• 4) Name of the person or entity responsible for managing such personal data:
  TESS Holdings Co., Ltd.
  6-1-1 Nishinakajima, Yodogawa-ku, Osaka-shi, Osaka
  Kazuki Yamamoto, Representative Director and President

10．Contact regarding Personal Information

For inquiries, correction, suspension of use, etc., of Personal Information, or to consult or make claims regarding the handling of Personal Information, please contact the following and we will promptly respond to the extent reasonable.

＜Personal Information Contact Information＞
TESS Holdings Co., Ltd.
Public Relations & Investor Relations Team
TEL: +81-6-6308-2794 FAX: +81-6-6308-2749

11．Compliance with Laws and Regulations

The Company will comply with all laws and regulations applicable with respect to Personal Information and the guideline of the Personal Information Protection Commission, and improve the actions set forth in the preceding sections as appropriate.

12．Other

The Company may change or revise the Policy without notice in accordance with the change in laws and regulations or change, etc., in our methods regarding protection of Personal Information.

Revised September 29, 2022