Privacy Policy

Sanden Corporation, its subsidiaries, and its affiliated companies, which together comprise the Sanden Group, will comply with the entirety of the Personal Data Protection Law of Japan, based on our Company Principles of acting in compliance with all laws and international rules at home and abroad. With the understanding that the protection of personal data is a corporate responsibility, the Sanden Group will act in good faith in all aspects of its business activities, and will commit to ensuring that we earn the trust of our customers and stockholders.
(This policy applies only to Sanden Group residing in Japan)

Policy Established on March 31, 2005

I. Treatment of Personal Data

1.The Sanden Group will acquire personal data by legitimate and fair means, and will use them only for the purposes specified when acquired, and to the
   minimum extent necessary in the performance of business.

2.If the Sanden Group shares personal data with any third parties, or outsources the treatment of personal data to any third parties, it will take proper
   measures to ensure that such data remain confidential.

3.Unless otherwise provided by law, the Sanden Group will not supply personal data to any third parties without the consent of the individuals concerned.

II. Security Measures

The Sanden Group will make every effort to ensure the security and accuracy of personal data, and to prevent the unauthorized access, destruction,
alteration, or leakage of such data.

III. Respect for Personal Rights

If the Sanden Group is requested by an individual to disclose, correct, suspend, or delete their personal data, it will respond in good faith and with respecting
Ifor that individual’s rights concerning personal data.

IV. Complete Control

1.The Sanden Group will ensure that personal data is treated in an appropriate and legitimate manner in the course of daily business activities.
   It will appoint personnel responsible for personal data management at each company, and instruct all officers and employees on the importance
   of protecting personal data.

2.The Sanden Group will always work to maintain and improve its management system for the protection of personal data.