Confidentiality Policy
Introduction
Japan EHS Audit Co., Ltd. (hereinafter referred to as "our company") recognizes that all information entrusted to us by our clients in the course of carrying out our EHS/ESG audit and consulting business is confidential and of the utmost importance. Building relationships of trust with our clients is the foundation of our business, and we believe that maintaining the confidentiality of the information entrusted to us is our absolute social responsibility. In order to fulfill this responsibility, our company has established the following confidentiality policy and declares that all officers, employees, and all parties involved in our business will comply with it.
Article 1 (Definition of Confidential Information)
In this policy, "confidential information" refers to any and all technical, business, financial, and other information of customers that is disclosed to us by our customers or that we learn in the course of performing our business, regardless of the means of disclosure (written, oral, electromagnetic recording medium, etc.) or whether the information is marked as confidential.
Article 2 (Handling of Confidential Information)
1. Prohibition of use for purposes other than those intended
We will not use any confidential information disclosed by our customers for any purpose other than carrying out business based on the contract with the customer.
2. Non-Disclosure to Third Parties
We will strictly manage confidential information disclosed by our customers and will not disclose or leak it to any third party without the customer's prior written consent.
3. Safety Control Measures
In order to prevent the leakage, loss, or damage of confidential information, we will take appropriate organizational, personal, physical, and technical safety control measures based on our information security policy.
Article 3 (Exceptions to the obligation of confidentiality)
Notwithstanding the provisions of the preceding article, we shall not be obligated to maintain confidentiality with respect to any information that falls under any of the following:
1. Information that was already publicly known at the time of disclosure
2. Information that becomes publicly known after disclosure through no fault of our company
3. Information that was already lawfully held by the Company at the time of disclosure
4. Information obtained lawfully from a third party with legitimate authority without any obligation to maintain confidentiality
5. Information independently developed by the Company without reference to disclosed confidential information
6. Information that is required to be disclosed by law or order of a court, government agency, etc. However, if we receive such an order, we will endeavor to notify you promptly.
Article 4 (Handling after contract termination)
The confidentiality obligations set forth in this policy shall remain in effect even after the contract with the customer is terminated. Furthermore, if requested by the customer after the contract is terminated, we will promptly return or destroy any confidential information that we have received in accordance with the customer's instructions.
Article 5 (Supervision of Officers and Employees)
We will provide appropriate training and supervision to our officers, employees, and business partners to ensure that they comply with this policy, and we will impose the same confidentiality obligations on all persons involved in our business.
Article 6 (Review of the Policy)
We will continually review and improve the contents of this policy in response to amendments to laws and regulations and changes in social conditions.
End
Established on August 1, 2025