Enactment Date: October 1, 2023

BEEATS CO.,LTD.

Representative Director and President, Matuhiro Kashiwagi

1. Purpose

BEEATS CO.,LTD. (hereinafter referred to as "the Company") recognizes that, given that we use many information assets in the provision of OMO marketing solutions and the management of employees (hereinafter referred to as "the Business"), appropriately realizing information security and striving to protect information assets is not only an essential requirement for promoting corporate activities under social trust, but also a significant social responsibility. Therefore, in view of the importance of cybersecurity, the Company has established this Information Security Policy (hereinafter referred to as "this Policy"), and will establish, implement, maintain, and improve an information security management system to specifically carry it out.

2. Implementation Items

In accordance with this policy and our cybersecurity management system, we will implement the following measures.

(1) Regarding Information Security Objectives

We will establish information security objectives that are consistent with this Policy, take into account applicable information security requirements, as well as the results of risk assessments and risk responses, and communicate them to all employees. Furthermore, we will review them periodically, as well as whenever there are changes in our environment, or even when there are no changes.

(2) Regarding the Handling of Information Assets

a) Access privileges shall be granted only to those who require them for their duties.
b) Management shall be conducted in accordance with legal and regulatory requirements, contractual requirements, and the provisions of our information security management system.
c) Information assets shall be appropriately classified and managed according to their importance in terms of value, confidentiality, integrity, and availability.
d) Continuous monitoring shall be implemented to ensure that information assets are appropriately managed.

(3) Regarding Risk Assessment

a) We will conduct risk assessments, implement appropriate risk responses for information assets judged to be the most important based on business characteristics, and introduce management measures.
b) We will analyze the causes of incidents related to information security and implement measures to prevent recurrence.

(4) Regarding Business Continuity Management

We will minimize business interruptions caused by disasters, malfunctions, etc., and ensure business continuity capability.

(5) Education

We will conduct information security education and training for all employees.

(6) Compliance with Provisions and Procedures

We will comply with the provisions and procedures of the information security management system.

(7) Compliance with Legal and Regulatory Requirements and Contractual Requirements

We will comply with legal and regulatory requirements, as well as contractual requirements regarding information security.

(8) Continuous Improvement

We will engage in the continuous improvement of the information security management system.

3. Responsibility, Obligations, and Penalties

The Representative Director shall bear responsibility for the information security management system, including this Policy, and employees within the scope of application shall have an obligation to comply with the established provisions and procedures. Employees who neglect their obligations or engage in violations shall be disciplined in accordance with the Work Regulations. For employees of partner companies, we will respond in accordance with individually established contracts, etc.

4. Periodic Review

The information security management system shall be reviewed periodically and as necessary to ensure its maintenance and management.