NHK Spring Co., Ltd. and NHK Group companies (hereinafter, the Company) actively utilize a variety of personal information collected from customers to ensure customer satisfaction and provide products and services at the highest level of global quality.

The Company has established the NHK Spring Group Privacy Policy to protect and maintain necessary and appropriate personal information. All company employees including executive management, full-time employees, temporary employees, and part-time employees must comply with this policy when handling and managing personal information. All third parties contracted to manage personal information on the Company's behalf must comply with this policy and are subject to strict supervision by the Company.

Personal information applicable to this policy is defined as all information obtained, learned, or stored during the Company's business activities. This also includes personal information related to the Company's employees.

• The Company shall establish an organization to ensure the protection of personal information, appoint a dedicated Personal Information Management Director, and commit to the proper management and protection of personal information.
• The Company shall establish rules and regulations regarding the appropriate handling of personal information regarding collection, use, and provision. All employees shall comply with these rules.
• If the Company contracts a third party to handle personal information, the Company shall filter the personal information given to the third party the absolute minimum amount required, select third parties deemed capable of handling personal information appropriately, and manage third parties appropriately including such activities as safe management of personal information, confidentiality obligations, prohibition of sub-contracting, and so on.
• The Company shall implement reasonable and appropriate safety measures regarding the management of stored or outsourced personal information to ensure prevention of divulgence, loss, or tampering.
• The Company shall comply with all national and other laws and regulations regarding personal information protection.
• The Company shall train all employees on the policy and executive management shall proactively engage in increasing understanding of this policy and improving awareness of personal information protection.
• The Company shall regularly and continually assess and review the personal information protection system including related regulations with the aim to improve this system.

Created: April 1, 2005
Revised: April 1, 2010

NHK Spring Co., Ltd.