Privacy Policy

ALCONIX Group (as specified in “9. Companies to which this Policy applies”) has established the following privacy policy (this “Policy”) in order to protect personal information (as defined in the applicable data protection laws; hereinafter the same shall apply), and handles personal information with the utmost care.

1. Acquisition of Personal Information

   ALCONIX Group shall specify the purposes of use and only acquire personal information to the extent necessary by using lawful and fair means.

   ALCONIX Group may acquire the following categories of personal data for the purposes specified in “2. Use of Personal Information.”

   1. Personal information concerning business partners (including candidates)
      Name, contact information (including, without limitation, email address, telephone number and fax number; hereinafter, the same shall apply), workplace, position/role, affiliated organization, bank deposit and withdrawal information, etc.
   2. Personal information concerning shareholders and investors
      Name, contact information, shareholding status, address, etc.
   3. Personal information concerning job applicants
      Name, contact information, school, address, date of birth, age, nationality, educational background, work experience, qualifications, etc.
   4. Personal information concerning ALCONIX Group’s directors, officers, employees, former employees and their family members
      Name, contact information, location data, online identifier (IP address, cookie identifier), position, bank account information, performance evaluation records, employment information (e.g., resume, certificates, address, spouse, dependents, date of birth, nationality and references), bank deposit and withdrawal information, etc.
2. Use of Personal Information

   After obtaining consent from the relevant identifiable person and satisfying other requirements as required under the applicable data protection laws, ALCONIX Group will use personal information within the scope of the following purposes of use:

   1. Personal information regarding business partners (including candidates)
      1. Conducting negotiations, referrals, contacts, agreements, order placements, order acceptances and settlements in relation to transactions, and other processing and management relating to transactions with business partners;
      2. Delivering and receiving ALCONIX Group’s products, services, etc. in transactions;
      3. Providing various information on guidance for events, exhibitions, etc. and other information relating to ALCONIX Group’s products and services;
      4. Improving the quality of ALCONIX Group’s products and services, and planning and development of new products and services;
      5. Conducting research and analysis of information relating to ALCONIX Group’s products and services;
      6. Handling customer inquiries, requests for information brochures, etc.; and
      7. Properly and smoothly performing ALCONIX Group’s business operations in relation to the above items.
   2. Personal information concerning shareholders and investors
      1. Performing functions concerning the rights and obligations of shareholders in accordance with the Companies Act and other applicable laws and regulations, and implementing various measures to facilitate a smooth relationship with shareholders;
      2. Providing information to investors concerning an overview of ALCONIX Group’s business, financial results, and various information sessions, etc.; and
      3. Properly and smoothly performing the ALCONIX Group’s business operations in relation to the above items.
   3. Personal information concerning job applicants
      1. Providing information and communications relating to recruitment activities, and screening and making decisions on hiring;
      2. Providing materials and communications for joining ALCONIX Group after making informal job offers;
      3. Promoting and implementing the ALCONIX Group's human resources strategy; and
      4. Conducting other labor management, and properly and smoothly performing ALCONIX Group’s business operations in relation to the above items.
   4. Personal information concerning ALCONIX Group’s officers, employees, former employees and their family members
      1. Conducting work-related communications, exchanges of information, and handling rights and duties relating to labor laws and regulations, tax laws and regulations and social welfare laws and regulations, such as human resource policies (including transfers, evaluations, and career development such as education), salary payment, attendance management and welfare benefits;
      2. Handling various procedures stipulated in internal regulations;
      3. Communicating with, and providing information to, the employee representative association, industrial machinery health insurance association, shareholding association, alumni club and group companies;
      4. Notifying and reporting to public offices, auxiliary organizations and other organizations to which ALCONIX Group belongs;
      5. Providing welfare benefit services, referrals concerning various types of group insurance, and other related procedures;
      6. Distributing internal publications, etc.;
      7. Providing communications during emergencies;
      8. Using, maintaining and managing information infrastructure;
      9. Conducting various analysis based on information infrastructure usage logs for the purpose of ascertaining the actual state of business operations and improving such business operations;
      10. Promoting and implementing the ALCONIX Group's human resources strategy; and
      11. Conducting other labor management, and properly and smoothly performing the ALCONIX Group’s business operations in relation to the above items.

      In addition to the above, ALCONIX Group may use the information for the following purposes in connection with ALCONIX’s business operations:

      1. Accepting visitors, inviting external guests, and other personal exchanges;
      2. Properly and smoothly performing the ALCONIX Group’s internal control and related operations;
      3. Implementing and reporting internal audits;
      4. Handling of whistle-blowing, etc., and implementing internal investigations and reporting based on whistle-blowing, etc.; and/or
      5. Purposes of use presented by ALCONIX Group upon the provision of personal information.
3. Provision of Personal Information to Third Parties

   Unless otherwise set forth in the applicable laws and regulations, ALCONIX Group will not provide personal information to third parties without obtaining consent from the relevant identifiable person.

   ALCONIX Group may provide personal information to a third party in a country other than the country in which the relevant identifiable person is located. Such country may not have the same level of personal information protection systems as the country in which the relevant identifiable person is located. ALCONIX Group will not provide personal information unless permitted by the applicable laws and regulations or unless ALCONIX Group has obtained consent from the relevant identifiable person pursuant to the method set forth in the applicable laws and regulations.

   For details of the measures taken by ALCONIX Group, please communicate with the contact desk specified in “8. Inquiries” below.

4. Joint Use

   ALCONIX Group may use personal information jointly within ALCONIX Group. However, ALCONIX Group shall not use jointly beyond the scope necessary to achieve the purpose of use.

   1. The purpose of use for joint users
      Same as provided in 2. above.
   2. Items of personal information that may be used jointly
      Same as provided in 1. above.
   3. Scope of the entities that will use information jointly
      ALCONIX CORPORATION and its affiliated companies of ALCONIX Group specified in 9.
   4. Entity and representative responsible for management of joint use
      ALCONIX CORPORATION
      2-11-1 Nagatacho, Chiyoda-ku, Tokyo 100-6112, Japan
      Hiroshi Teshirogi
      Representative Director, President and CEO
5. Management of Personal Information

   ALCONIX Group has taken necessary and appropriate measures to prevent the leakage, loss or damage of personal information provided to ALCONIX Group, and for other safety management purposes. For details of the measures taken by ALCONIX Group for managing the security of personal information, please communicate with the contact desk specified in “8. Inquiries” below.

6. Personal Information Training

   ALCONIX Group has established internal regulations for the protection of personal information, implements such internal regulations by thoroughly informing the same to all of the ALCONIX Group’s employees (including general officers and employees, part-timers, dispatched workers, etc.) and other related parties, and will improve and maintain such internal regulations.

7. Disclosure, Correction, Suspension of Use, Etc. of Personal Information

   When ALCONIX Group receives a request from an identifiable person or his/her representative to exercise his/her rights under the applicable laws and regulations (such as notification of purposes of use, disclosure, correction, addition, deletion, suspension of use, erasure, or suspension of provision to a third party) with respect to personal information held by ALCONIX Group, ALCONIX Group will appropriately handle such request pursuant to the applicable laws and regulations. For the detailed procedures regarding these requests, please communicate with the contact desk specified in “8. Inquiries” below.

   Procedures, etc., for “requests for disclosure, correction, deletion, etc.,
   concerning personal information”

8. Inquiries

   Inquiries regarding personal information held by ALCONIX Group will be handled by the general affairs and human resources departments of the group companies that provided the personal information.

   Sanno Park Tower 12th floor, 2-11-1 Nagatacho, Chiyoda-ku, Tokyo 100-6112
   Personal information inquiries desk, ALCONIX CORPORATION
   FAX：03-3596-7456　Email：privacy@alconix.com

9. Companies to which this Policy applies

   ALCONIX CORPORATION
   ADVANCED MATERIAL JAPAN CORPORATION
   HAYASHI METAL CORPORATION
   OHKAWA CORPORATION
   ALCONIX MITAKA CORPORATION
   ALUMINUM & COPPER RECYCLING CENTER CORPORATION
   OHBA SEIKEN CO., LTD.
   TOKAI YOGYO CO., LTD.
   HEIWA KINZOKU CO., LTD.
   MARKTEC CORPORATION
   FUJI PRESS CO.,LTD.
   FUJI CARBON MANUFACTURING CO.
   FUJINE INDUSTRY CO., LTD.
   ALCONIX VENTURES CORPORATION
   AC METALS CORPORATION
   JUPITER INDUSTRY CO., LTD.
   SOODE NAGANO CO., LTD.
   SAKAMOTO ELECTRIC MFG.CO.LTD.

10. Others

    ALCONIX Group reserves the right to change, modify or add to this Policy without prior notice as necessary at the ALCONIX Group’s discretion or due to the revision or abolition of applicable laws and regulations. ALCONIX Group shall not be responsible for the protection of personal information on any external websites linked to the ALCONIX Group’s website; thus, please check the privacy policies of each relevant website.

    Privacy Policy of Overseas Consolidated Subsidiaries of Alconix

Revised April 1, 2026