SGH

Information Security Basic Policy

SG Holdings Co., Ltd. (the "Company"), aiming to contribute to economic development and striving to be a business broadly useful to society, considers the protection of the Company's information assets, including the information received from customers, a key social responsibility and to that end has formulated the Information Security Basic Policy (the "Basic Policy") shown below. The Company continues to work to effectively implement and enhance information security.

Enactment and Implementation of Internal Rules

The Company will establish information security regulations and other relevant regulations based on the Basic Policy and implement information security measures.

Establishment of an Information Security Management System

The Company will establish a management system for ensuring information security and also build and employ a system for coordinating as necessary with external entities.

Information Security Measures

The Company will adopt appropriate information security measures and work to prevent alteration, loss, leakage, improper access or other interference with the use of information assets.

Continuing Education

The Company will work to ensure that all officers and employees, etc. are fully cognizant of the Basic Policy and will conduct necessary education on information security on an ongoing basis.

Incident Response

If an information security incident occurs, the Company will promptly investigate the cause, work to prevent the expansion of damage and take steps to prevent a reoccurrence.

Compliance with Laws and Regulations, etc.

The Company will strictly comply with all laws and regulations and internal rules, etc.

concerning information security.

Evaluation and Review of Information Security Activities

The Company will periodically review whether information security is being appropriately enforced and supported and implement remedial measures as needed.

Effective September 21, 2014