Sumico Lubricant Co., Ltd. （hereinafter referred to as “our company”） declares to comply with laws and regulations inside and outside Japan, under the "Compliance with Laws and Regulations" in the Sumitomo Metal Mining Group （hereinafter referred to as “SMM Group”）Code of Conduct.
Under this Code of Conduct, our company has established the following privacy policy to properly handle personal information, in compliance with laws concerning personal information protection and related ordinances （hereinafter referred to as "laws and ordinances"）. The Company will strive to protect your personal information through adherence to this privacy policy by its corporate officers and employees.

1.Name and address of business

Sumico Lubricant Co., Ltd.
11-3, Shimbashi 5-chome Minato-ku, Tokyo 105-0004, Japan (Shimbashi Sumitomo Building 7F)
Please refer to the corporate information available via the link below including the name of the representative and other information.
https://www.sumico.co.jp/e/

2. Compliance with applicable laws, regulations, guidelines, etc.

Our company appropriately handles personal information by complying with laws, regulations, and guidelines such as those of the Personal Information Protection Commission.

3. Purpose Specification

When our company obtains personal information, other than when exempted by law or regulation, the Company shall announce or give notice (including announcement via this Policy) of the purpose of use, or, in the case of personal information obtained directly from a person through that person writing it on a contract or other document (including electromagnetic records), our company shall disclose the purpose of use in advance, and obtain the information by fair and lawful means.

Except in cases where our company has made a separate, individual announcement or notification, our company shall use personal information appropriately within the scope necessary to achieve the following purposes of use.

(1) Personal information concerning a customer who has made an inquiry through our company's website

• To respond to, confirm, and/or make records of inquiries or consultation
• To provide information concerning our company's products, services, exhibitions, etc.
• For identity verification
• To implement and analyze questionnaires and campaigns
• For the development of our company products and services
• To prevent, investigate, and identify scams, cyberattacks, and other potential illegal or fraudulent actions, and protect the rights and interests of our company and third parties
• To investigate and deal with actions that are prohibited by the terms of use of our company's website, etc.

(2) Personal information concerning business partners (in the case of corporations, their officers and employees)

• For contact required by business, fulfillment of contracts, business negotiations, etc.
• For management of business partner information

(3) Personal information concerning shareholders (in the case of corporate shareholders, their officers and employees)

• To exercise rights and fulfill duties based on the Companies Act
• To provide various benefits in accordance with shareholders' status
• To implement policies that facilitate the relationship between shareholders and our company
• For record-keeping, notifications to government agencies, reporting, and other such actions for fulfillment of duties and management of shareholders based on various laws and regulations

(4) Personal information concerning hiring/recruitment activity applicants

• For contacting and providing information to hiring/recruitment activity applicants
• For other uses necessary to hiring/recruitment activities

4. Joint use

Our company may share the following personal information with a third party in some situations.
For inquiries concerning joint use, please utilize the inquiry contact in 10. below.

(1) Information that may be shared:
    (a) Name
    (b) Address
    (c) Company/organization
    (d) Telephone number
    (e) E-mail address
    (f) Details of inquiry

(2) Parties with whom the information may be shared:
Sumitomo Metal Mining Co. Ltd. (“SMM”) subsidiaries and affiliates
(information on SMM subsidiaries and affiliates is available from the link below)
Domestic Group Companies | Corporate Information | Sumitomo Metal Mining Co., Ltd. (smm.co.jp)
Overseas Group Companies | Corporate Information | Sumitomo Metal Mining Co., Ltd. (smmco.jp)

(3) Purpose of use by SMM subsidiaries and affiliates:
The purpose of use of shared information is as per 3 above.

(4) Personal information manager:
Sumico Lubricant Co., Ltd.
11-3, Shimbashi 5-chome Minato-ku, Tokyo 105-0004, Japan (Shimbashi Sumitomo Building 7F)
https://www.sumico.co.jp/e/

5. Security Control Measures

For the security control of personal information, our company takes the following measures to prevent unauthorized access, leakage, loss, or damage of personal information.

(1) Internal security control measures
Our company takes the required and appropriate measures to ensure the security control of the personal information we handle, such as implementing mechanisms to protect information systems that handle personal data from unauthorized access by external parties and from malicious software.

(2) Supervision of employees
In order to ensure the security control of personal information that is handled by our company employees (“employees” in this paragraph refers to directors, audit & supervisory board members, and temporary employees as well as our company employees), our company shall implement the necessary and appropriate supervision, including establishment of personal information handling rules for employees and internal recording systems, inspections of the state of personal information handling, and provision of training to employees.

(3) Supervision of outsource companies
In cases where the handling of personal information is to be outsourced in whole or in part, our company shall conclude the necessary contracts with outsource companies and shall implement the necessary and appropriate supervision, including inspections of the state of handling, in order to ensure the security control of personal information.

(4) Understanding of the external environment
When handling personal information overseas, our company shall gather information to gain an understanding concerning the protection of personal information in the relevant country, and shall take measures for security control on this basis.

6. Restriction of Provision to a Third Party

Our company shall not, except in cases in which the provision of personal data is based on laws and regulations, provide personal data to a third party without obtaining the prior consent of the person.

7. Relation to Other Privacy Policies

In our company, in addition to this Privacy Policy, other privacy policies may be established by each business segment. In such cases, such other privacy policies take priority over this Privacy Policy.

8. Continuous Improvements of the Regulations

Our company has established in-house regulations concerning personal information protection, and shall strive to make continuous improvements to such regulations by reviewing them.

9. Requests for disclosure, etc., of personal information

When our company receives a request for the disclosure, correction, cessation of use, deletion, etc., of personal information, our company shall act promptly after confirmation by a prescribed procedure that the requesting person is the person in question.
Please contact the inquiry contact in 10. below with any questions concerning this policy or to exercise rights concerning your personal information.

10. Inquiry contact

Please use the contact below for questions or complaints concerning our company's handling of personal information.
tel. +81-3-5425-6702, 9:00 to 17:00 on Monday through Friday (except holidays)

Established: November 15 2022
Sumico Lubricant Co., Ltd.