E-mail Membership Agreement for IR STREET Mail by Finantec

Article 1 (General rules)
1. This agreement covers all items concerning the use by e-mail members (“Members”) of the corporate IR information service provided by Finantec Co., Ltd. (“FT”).
2. FT may revise this agreement without the consent of the Members. In this case, Members will use this Web site in accordance with the revised terms of use. The revised agreement will become effective at the time that it is posted on the Internet.
3. Members may register at no cost, but they must first agree to the terms of this agreement.
4. Members are responsible for maintaining computers and/or other equipment needed to access this service.
5. Members must make a sincere effort to comply with the terms of this contract.


Article 2 (Service)
1. The service provided by FT is the distribution of news releases of listed companies to the e-mail addresses of the Members who are already registered on the FT Web site.
2. Due to the technological nature of the Internet and e-mail distribution systems, as well as to the regulations of individual Internet service providers and to other factors, there may be a delay between the time that information distributed as described in the above paragraph is sent by FT and the time that it reaches each Member. FT accepts no responsibility whatsoever for any damages incurred by a Member due to this delay.


Article 3 (Membership)
1. Members must be individuals.
2. Members are individuals who have accepted the terms of this agreement and completed a membership application form that has been accepted by FT. However, FT may reject membership applications in cases where it decides that a problem exists.
3. FT may cancel a membership in cases where a Member’s conduct is improper. In addition, in cases where a Member provides a third party with information using this service, or with information from this service that has been edited or altered in any way, FT may initiate litigation to recover damages resulting from illegal acts.
4. Members must swiftly submit notice of changes in membership information using the method prescribed by FT. FT accepts no responsibility whatsoever for interruptions in the service to a Member resulting from such a change.


Article 4 (Approval of membership application)
FT will approve membership applications after confirming that all required information has been entered and then initiate the service. However, FT is not obligated to approve any application.


Article 5 (Rejection of membership application)
FT may reject a membership application with no explanation in any of the following cases.
(a) When there are fraudulent, mistaken or missing entries in the prescribed membership application form, or when the individual listed does not exist
(b) When an entry has been falsified
(c) In other cases that FT views as reason for rejection


Article 6 (Suspension of service provision)
FT may suspend the provision of the service immediately and with no prior notice in any of the following cases. Furthermore, FT accepts no responsibility whatsoever for damages to the Member resulting from this suspension.
(a) When fraudulent information has been registered, or when there is the suspicion of fraud
(b) When the registered e-mail address has been used improperly, or when there is the suspicion of improper use
(c) In other cases where FT decides that service should be suspended due to a violation of any part of this agreement


Article 7 (Expiration of Membership)
1. Memberships will be valid from the day the membership application is approved until the member submits a notice of cancellation. However, a member’s privileges will be lost in the event of a violation listed in Article 3, Paragraph 3 or Article 12, paragraph 3.
2. A member may use this service from the time that FT approves the applicable membership application.


Article 8 (Management of e-mail service)
1. With regard to their rights to receive this service or any other rights concerning this service, Members may not change or transfer the registered name or use the service for a third party. Furthermore, members may not loan, reuse, buy or sell, or use as collateral rights to this service.
2. Members are responsible for managing their respective e-mail addresses. FT accepts no responsibility whatsoever for damages resulting from mistakes, forgery, alteration, theft or other misuse of e-mail addresses.
3. In cases where a Member discovers that its e-mail address has been stolen or lost or is being used by a third party, the Member must immediately notify FT of this fact and follow FT’s instructions.
4. Members may not transfer, rename, buy or sell, use as collateral or loan their e-mail addresses.


Article 9 (Revisions in services and suspensions or termination of services)
1. FT may alter the content of this service, the times of its availability and other items without prior notice to Members.
2. FT may suspend, terminate or otherwise alter the provision of this service without prior notice to Members in the event of an unavoidable problem concerning the maintenance, inspections and other use of servers, communication equipment and other systems used to provide this service. FT accepts no responsibility whatsoever for damages resulting from such suspensions or terminations.
3. FT may, at its own discretion, suspend all or part of this service in the event of a natural disaster, serious incident or other emergency, or in the event that such an event is likely to occur. FT accepts no responsibility whatsoever for damages resulting from such suspensions.


Article 10 (Restrictions of use)
1. FT retains all copyrights, rights of use and other rights concerning the provision of this service.
2. Members may not reuse, copy, store, view, display, transfer, sell, redistribute, republish or perform any similar event involving the information provided by this service, as well as edited or altered information from this service, without the prior written consent of FT. In addition, Members are prohibited from leaking such information to third parties in any manner.


Article 11 (Prohibited behavior, etc.)
1. Members are prohibited from violating the terms of this agreement, conducting immoral acts, conducting other acts in violation of laws and regulations, and conducting illegal acts with regard to third parties. In addition, the Member will be fully responsible for all damages and losses at third parties resulting from any of these prohibited acts.
2. FT accepts no responsibility whatsoever concerning damages and losses resulting from acts described in the above paragraph. In cases where FT incurs damages due to a Member’s actions, FT may initiate litigation to recover damages.
3. FT may take legal actions to demand the halt of illegal acts by Members, such as infringement of copyrights, logotypes and other registered trademarks and violations of the Law to Prevent Illegal Competition.
4. When FT discovers that a Member has participate in a crime or an immoral act, or when there is the suspicion of such violations, FT may disclose the Member’s personal information in accordance with requests from law enforcement agencies or court orders.


Article 12 (Cancellations, etc.)
1. This agreement may be terminated at any time at the discretion of FT or the Member.
2. If the Member terminates this agreement, the Member must notify FT of the desire to terminate use of the service in writing, using the designated Web site, by e-mail or by another method specified by FT. If FT terminates this agreement, FT must notify the Member of the desire to terminate the agreement in writing, using the designated Web site, by e-mail or in another method that FT believes is appropriate.
3. In any of the following cases, FT may suspend at any time the provision of all or part of this service as prescribed in this agreement without prior notice to the Member, or FT may cancel all or part of this agreement.
(a) When a violation of this agreement or other event occurs that requires FT to terminate the service
(b) When there is a death or disappearance of a Member
(c) When FT is unable to contact a Member because the Member neglects to notify FT of a change in the e-mail address or other item


Article 13 (Self-Responsibility)
1. Members will reach final decisions concerning investments on their own. FT accepts no responsibility whatsoever for any losses and gains resulting from Members’ securities transactions based on decisions that use information provided by this service.
2. The contents of this service may include erroneous data, data that was input incorrectly and other mistakes. FT may revise or alter such data at any time.
3. Final investment decisions will be reached by Members or investors themselves. FT accepts no responsibility whatsoever for any losses and gains at Members resulting from mistaken information and data described in the above paragraph. Members will use this service based on a correct and adequate understanding that FT makes no guarantee concerning the veracity or accuracy of the information provided by this service.


Article 14 (Notices)
1. FT will use its designated method to send notices to Members using the e-mail addresses provided by Members.
2. When FT sends a notice to Members’ e-mail addresses, the notice shall be deemed to have arrived at the normal time even if the notice has not arrived due to a rejection by the e-mail service provider or any other reason.


Article 15 (Legal jurisdiction)
1. This agreement is subject to the laws of Japan.
2. Resolutions of disputes concerning this agreement will be submitted solely to the applicable court with jurisdiction where FT has its head office.


Article 16 (Personal information)
FT will handle Members’ personal information in accordance with its personal information protection policy and privacy policy (provided separately).


Article 17 (Removal of services)
FT may, at its discretion, remove specific services for any reason. FT accepts no responsibility whatsoever for damages resulting from the removal of a service.


Masaki Kai
CEO

Finantec Co., Ltd.
February 4, 2005


Finantec Personal Information Protection Policy

With regard to the protection of all personal information handled in the course of its business operations, Finantec(“FT”) is committed to fulfilling its social obligations by strictly complying with laws and regulations for protecting the rights of information sources and protecting personal information.

FT has established a compliance program for the policy outlined below. We are constantly improving our personal information protection management systems by using the latest advances in information technology, reflecting shifts in social demands and the operating environment, and responding to other changes. I pledge that our entire organization will remain dedicated to making these improvements as required.

Personal information will be collected, used and provided solely for the purposes of conducting proper business activities and for recruiting and managing employees.

We will constantly upgrade our personal information security system with regard to risks such as the unauthorized access of personal information as well as losses, falsification, leaks and other improper handling of this information. We will accomplish this by allocating corporate resources in a manner that reflects the nature of our operations so as to put in place reasonable safety measures.

FT will strictly comply with laws and regulations concerning the protection of personal information as well as with standards for ethical behavior.

FT will constantly make improvements in its compliance program by conducting appropriate and timely reviews. These reviews will reflect changes in our operating environment, such as shifts in the needs of information sources and advances in information technology.

This policy is distributed to all executives and employees and training programs conducted to ensure that these individuals understand the contents of this policy. We are determined to maintain a high level of awareness of the importance of protecting personal information.



Masaki Kai
CEO
Finantec Co., Ltd.

February 4, 2005

Finantec Privacy Poricy

Article 1 (Purposes of using personal information)
Finantec(“FT”) will use the personal information it collects for the following purposes. In all cases, FT will follow its compliance program and, in accordance with this privacy policy, exercise extreme care when handling personal information.
(1) Confirmation of application to receive services and provision of services
・Confirmation of applications for events and seminars and delivery of tickets and other items
・Confirmation of registration for corporate IR information service and commencement of IR STREET Mail service.
・Confirmation of registrations for membership services and provision of services
・Intermediary services, such as handling requests for materials from companies placing advertisements
・Delivery of gratuities and other items concerning surveys in which members have participated
・Delivery of prizes and other items concerning drawings and other events in which members have participated

(2) To ask for cooperation concerning FT services
・Requests for participation in surveys and questionnaires
・Requests for participation in various events
・Provision of various types of information from client companies

(3) To provide/improve current services and develop new services
・Improve services, Web sites and other items from the standpoint of customers
・Customize services, Web sites and other items to meet the needs of individual users
・Conduct surveys to determine user satisfaction concerning services ordered and other items
・Statistically compile personal information and make the results public as the results of a survey
・Monitor the use of services in order to improve services and develop new services

(4) To distribute information concerning products and services provided by FT
・Distribution of information concerning services provided by FT
・Monitor the use of FT products and services, Web sites and other items and provide useful information, surveys and other items from companies and organizations in response to user requests

(5) To provide information on major shareholders that is disclosed in securities reports, prospectuses and other publications for the purpose of distributing shareholder information about publicly owned companies
・FT may revise registered information in cases where there has been a change in this information, such as in the name of a city, a postal code or a financial institution, that prevents the delivery of a product or of a request.
・FT may manage personal information that it collects in association with other information that it manages. For example, FT may compare registered e-mail service users with seminar participants to determine the percentage of these users who attended a seminar.


Article 2 (Provision of information to third parties)
FT will not provide personal information to third parties without the consent of the users involved.
FT will not disclose or provide personal information to companies and organizations without the consent of the users involved even in cases where FT believes that provision of this information as an intermediary would be beneficial to these companies and organizations.
FT may provide results of surveys and questionnaires as well as compilations and analysis of characteristics of respondents, but not including personal information, to parties that request such surveys and questionnaires. In this case, FT will not provide any information that would reveal the identities of any individual users.
FT may disclose or provide personal information to a company or organization in the following cases where a user: submits a request or order using FT to another company or organization for information, a service, a product, a response to a solicitation, a contact or an intermediary service; submits an application for an exhibition or seminar involving another company or organization; or asks FT to serve as an intermediary concerning a request for materials to a company that has placed an advertisement.
FT may disclose personal information when legally required or when FT believes such disclosure is necessary in order to protect and preserve the rights, financial interests and safety of users.


Article 3 (Outsourcing and handling of entrusted information)
When FT outsources the collection of personal information to a third party, FT will strictly supervise the handling of personal information by this third party based on a contract and other means in order to ensure the safety of that information. In addition, when FT is entrusted with personal information by a customer or other party, FT will endeavor to establish an effective framework for receiving this information and will, based on a contract, ensure the safety of customers’ information. Moreover, FT will appoint a personal information protection officer who will strictly store, manage, return and delete this information.


Article 4 (Management of personal information)
Personal information collected by FT will be handled safely based on strict management in accordance with FT’s compliance program. In addition, FT will do its best to execute information security measures to ensure the accuracy and safety of personal information as well as to prevent unauthorized access to personal information and losses, falsification, leaks and other improper handling of this information.


Article 5 (Personal information disclosure, revisions and deletions and termination of provision to third parties)
FT will do its best to keep personal information accurate and up to date. When receiving applications from individuals, FT will verify an individual’s identity based on a message from the registered e-mail address and disclose the registered information. When a user notifies FT of an error in that individual’s personal information, FT will check the applicable information and, as necessary, make additions, changes, revisions or deletions (termination of membership) to the registered information. In some cases, however, the deletion of a registration may prevent FT from providing a product or service. Moreover, FT will comply a request from a user to terminate the provision of that individual’s personal information to third parties.
For matters concerning FT products and services, users are asked to refer to the contact information provided for each product or service.


Article 6 (Links to external sites)
FT’s Web sites incorporate links to other sites. FT is not responsible for the protection of personal information or the contents of these linked sites.


Article 7 (IP addresses and cookies)
(1) FT will use user IP addresses recorded in its log primarily for the following purposes.
・To identify the causes of server problems and resolve those problems
・To manage Web sites

(2) Some FT Web sites use cookies. Cookies are small data files sent to the browsers of site users and stored on users’ hard disks. The use of cookies makes it possible to keep a record of the pages a user views and of other information. FT uses cookies mainly for the following purposes.
・To customize the contents of e-mail and other items
・To provide services that match the interests of users
・To count the number of unique users
・FT may publicly disclose aggregate data produced by statistically processing information received from cookies
(Aggregate data will include no information that would reveal the identities of individual users.)

Note: Users can set their browsers to reject cookies or to display a warning when a Web site sends a cookie. Users should be aware that the refusal to accept cookies may limit or prevent their ability to use the services of FT Web sites.


Article 8 (Inquiries)
Questions and other inquiries concerning the protection of personal information at FT should be submitted to the FT personal information management officer.


Article 9 (FT department responsible for personal information management)
Personal Information Management Group
Finantec Co., Ltd.
4F, Annex, Kabutocho Kaisei Bldg., 13-1 Kabutocho, Nihonbashi, Chuo-ku, Tokyo 103-0026, Japan
E-mail: privacy@finantec-net.com


Policy established: February 4, 2005
Latest revision: May 31, 2006