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Policy on Protecting the Personal Information of Shareholders

The Company handles the personal information of shareholders (hereinafter the "Shareholders' Personal Information") based on the policy described below.
In the policy, "shareholders" means shareholders (including for the purposes of this policy, beneficial shareholders) and registered pledgees, odd-lot shareholders, and their legal representatives who are listed or recorded in the list of shareholders, the list of beneficial shareholders ("the List of Shareholders Etc."), or the register of fractional shares.

1. Handling of Shareholders' Personal Information

  1. Purpose of the Company's use of Shareholders' Personal Information
    The Company uses its Shareholders' Personal Information for the following purposes:
    • To exercise rights and fulfill obligations under the Companies Act
    • To provide favors to people holding the position of shareholders
    • To take steps to facilitate the relationship between the Company and its shareholders as a corporate judicial person and constituent members of the corporate judicial person
    • To manage shareholders, for example through the creation of data of shareholders under criteria prescribed in laws and regulations
    If the Company receives Shareholders' Personal Information directly from shareholders in writing, it will clearly specify the purpose of the use of the information unless the use is stipulated in Article 18, Paragraph 4 of the Act on the Protection of Personal Information (the "Personal Information Protection Law"). This shall not apply in the cases specified in Article 16, Paragraph 3 of the Personal Information Protection Law.
  2. Provision of Shareholders' Personal Information to third parties
    The Company will not provide Shareholders' Personal Information received from shareholders to any third parties, except in the cases stipulated in Article 23, Paragraph 1 and Article 23, Paragraph 4 of the Personal Information Protection Law.
  3. Shared use of Shareholders' Personal Information
    The Company will not share Shareholders' Personal Information received from shareholders with any specific parties.
  4. Inquiry for the Shareholders' Personal Information of the Company
    If you have any inquiries about the Company's handling of Shareholders' Personal Information, please contact us at the address below by mail or by e-mail. We do not accept inquiries in person.
    Inquiry section for Shareholders' Personal Information
    Investor Relations, Accounting and Finance Department
    NTT Urban Development Co.
    Akihabara UDX, 4-14-1 Sotokanda, Chiyoda-ku, Tokyo 101-0021
    E-mail address: nttud-ir@nttud.co.jp

2. Compliance

In handling Shareholders' Personal Information, the Company will comply with the Personal Information Protection Law and related laws and regulations, and the guidelines of supervising ministries and agencies and of the industry.

3. Security steps

The Company will take appropriate organized, personal, physical, and technical security steps in handling Shareholders' Personal Information.

4. Continuous improvement of the management system

The Company will actively protect Shareholders' Personal Information, reviewing the management system and regulations regularly, continuously, and flexibly and enhancing the management system appropriately and in a timely fashion in accordance with changes in the technical and legal systems.

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