Enacted: March 31, 2005
Last Revised: June 29, 2010


DECLARATION OF PROPER MANAGEMENT AND PROTECTION OF PERSONAL INFORMATION

At East West Consulting K.K., we believe that it is our social responsibility to safeguard the personal information of our candidates in order to continue operating reliable business as an executive search firm in the future. For this purpose, we have established the following guidelines for protecting personal information. All of us at East West Consulting will comply with these policies, make our best efforts to prevent the loss, falsification, tampering or leakage of personal information, take immediate and appropriate actions in cases that such accidents do occur, and strive for proper handling, management and maintenance of personal information.

1. On Obtaining Personal information:
East West Consulting K.K. ('EWC') will obtain personal information by legally acceptable and fair methods through our registration Web site, personal interviews, etc. The personal information that EWC will obtain includes, but is not limited to, such contact information (names, contact info, etc.) as required to enable us to identify particular individuals for our employment or for introduction of our candidates to clients and such career information (desired job and industry types, skills and certifications, educational background, work history, etc.) as required to implement our executive search services. The provision of the information is voluntary; when providing us with your personal information, please ensure that you read our privacy policy and understand its contents beforehand. If you decide not to provide us with necessary personal information, then please understand that such deed may cause hindrance to our provision of executive search services to you and/or our hiring of you as an employee at EWC.

2. On Using Personal information:
As for personal information for identification, EWC will use it for identifying and contacting relevant individuals when providing executive search services to clients and when hiring employees. As for other types of personal information, EWC will use it for matching the needs of client companies for executives and professionals, to the skills and qualifications of the candidates, for the purpose of introducing the latter to the former. We at EWC shall consider our business engagements and scale and shall not handle such personal information that goes beyond the scope of our business engagements; we shall also take necessary measures required for that end.

3. On Providing Personal information:
EWC will not provide any third party with personal information without prior approval obtained from the candidate to whom the personal information belongs to, unless otherwise stated in the laws and regulations of Japan or unless we have already obtained the consent of the candidate.

4. On Properly Managing the Safety of Personal information:
EWC will always safeguard and keep the personal information thus obtained accurate by constant updating. We take reasonable information security measures against illegal access and invasion of computer viruses, in order to protect the information against loss, destruction, falsification, leakage, etc. Should such incidents occur, EWC shall take appropriate actions in a most timely manner, according to our policies and countermeasures for emergencies regarding personal information.

5. On Disclosing and Making Corrections etc. to Personal information:
EWC understands that candidates have the right to request disclosure, correction, change, deletion, etc. of the registered data which belongs to themselves, and, when those requests be made, EWC shall respond within a reasonable time frame to such requests which are legitimate. Please contact us at the address below if you would like the disclosure, correction, etc. of your personal information. In such cases, we reserve the right to verify your identify. However, in the following cases, EWC might not take the above action: cases in which disclosure might harm the life, body, property and other rights and interests of the person or the third party; cases in which disclosure might noticeably impede the proper execution of the operations of the business entity concerned; cases in which disclosure violates laws. Where disclosure is regulated by laws and other regulations, we shall take appropriate actions according to the applicable laws.

6. On Our Structure to Safeguard Personal information:
EWC has established an internal organizational structure to ensure proper management of personal information, by such measures as nominating a Personal Information Protection Officer and other personnel involved in management of personal information, and so on. EWC will implement thorough education and training programs as to how to manage and handle personal information in a proper way for their daily business activities, in order to prevent, in advance, unauthorized disclosure of personal information and other illegal actions, as well as to enhance the proper handling structure of personal information with the company.

7. On Complying with Laws, Guidelines and Other Codes Stipulated by the Japanese Government:
EWC shall comply with all laws, guidelines and regulations concerning the protection of personal information, specifically stipulated by the Japanese government, as related to our businesses.

8. On Formulating, Implementing and Complying with the Personal Information Protection Management System:
EWC shall formulate a personal information protection management system for the protection of personal information, which is based on "Personal information protection management systems - requirements" (JIS15001:2006), as well as various other laws and regulations regarding the handling of personal information. EWC shall thoroughly implement and maintain this system for the entire company. Additionally, EWC shall consider, analyze and discuss opinions and requests from within and outside of the company to update and improve the system on a regular and continuous basis.

Please contact below if you have any complaints regarding our handling of personal information, or would like to consult, express opinions or ask questions regarding personal information.

Personal Information Customer Service Representative
East West Consulting K.K.
Chichibuya Bldg., 3-7-4 Kojimachi, Chiyoda-ku, Tokyo 102-0083
TEL: 03-3222-5531 (main)
E-mail: eastwest@ewc.co.jp

Information on Our Personal Information Protection Officer
Manager, Administration Division
East West Consulting K.K.
TEL: 03-3222-5531 (main)
E-mail: eastwest@ewc.co.jp

Information on our Authorized Personal Information Protection Organization
Name: Japan Information Processing Development Corporation (JIPDEC)
Contact: Personal Information Protection Consultation Service Office
Address: Kikai-Shinko Kaikan, 3-5-8 Shibakoen, Minato-ku, Tokyo, 105-0011, Japan
TEL: 0120-700-779


Nobuko Muromatsu
President, East West Consulting K.K.



DETAILED INFORMATION ON THE PROVISION OF PERSONAL INFORMATION

Information to be provided to the third parties:
Of all personal information obtained, as for personal information for identification, EWC will use it for identifying and contacting relevant individuals when providing executive search services to our clients and when hiring employees. As for other types of personal information, EWC will use it for matching the needs of client companies who are in need to executives and professionals, on one hand, and skills and qualifications of the candidates, for the purpose of introducing the latter to the former.

Methods of providing personal information:
When providing the above personal information to third parties, EWC shall mainly use e-mails to send the information to them. In doing so, EWC shall employ appropriate measures regarding sending and receiving of personal information, in order to ensure security of the information handled. Types of recipients to whom we provide personal information: EWC shall provide personal information to client companies who look for and wish to hire executives and professional personnel.

Types of recipients to whom we provide personal information:
EWC shall provide personal information to client companies who look for and wish to hire executives and professional personnel.

Agreements on properly handling personal information:
On the agreement contracts that EWC signs with the client companies to which we provide personal information, it is set forth that neither party is allowed to disclose any confidential information (including personal information) obtained from the other party and that the above prohibition will remain in effect even after the above agreement expires.


DETAILED INFORMATION OF EWC'S SECURITY MEASURES FOR PROTECTION PERSONAL INFORMATION

About information safety on EWC's Website:
EWC uses Secure Socket Layer (SSL) technology to encrypt information data sent from its registration page. In addition, on the EWC website, a firewall is always in effect in order to prevent deeds such as illegal access from outside parties and interception of information from occurring.

About access log:
EWC shall obtain access log information of the visitors to the EWC website. The information obtained, such as IP address and access time/date, shall be used for the sole purpose of understanding how EWC's Website is used and of collecting and analyzing the information for planning and improving our services. For no other purposes shall the information obtained be used.

About Cookie:
The EWC website does not use cookies, which are texts sent by a server to a Web browser and then sent back unchanged by the browser each time it accesses that server, and which are used for authenticating, tracking, and maintaining specific information about users.

About links to non-EWC Websites:
The EWC website provides links to various business entities and organizations, information sites, etc. However, EWC shall assume no liability regarding how personal information is handled on those Web sites.