PRIVACY POLICY

Mitsui Energy Development Co., Ltd. (MOECO) considers the protection of personal information as an important matter in our business activity and MOECO shall handle,
maintain, and control personal information based on the following personal information protection guidelines.

1.Our name, address, name of representative

Mitsui Energy Development Co., Ltd.
Otemachi One Mitsui&Co. Building 14F 2-1,
Otemachi 1-chome, Chiyoda-ku, Tokyo 100-0004, Japan
Hidenori Harada, President and Representative Director

2.Acquisition, use and provision of personal information

When acquiring personal information, MOECO will announce and notify the person of the purpose of use. In addition, when personal information to be described or recorded in a contract or other document is directly obtained from the person, MOECO will clearly indicate the purpose of use to the person in advance and obtain the personal information by legal and fair means.

3.Purpose of use of personal information

MOECO uses personal information for the following purposes:

  • （1）Personal information of business partners
    • ・Contact details, meetings, negotiations, etc.
    • ・For marketing research and analysis
    • ・For access control to our office
    • ・For payment procedures and contract fulfillment
    • ・For tax calculation, filing and payment
  • （2）Personal information of our officers, employees, and their family members, former officers, former employees, and their family members, as well as temporary staff and on-site personnel (hereinafter referred to as "officers and employees, etc.")
    • ・To conduct labor/personnel management in relation to work and operations, personnel deployment, performance evaluation, personnel training, welfare, safety and health
    • ・To withhold income tax, etc.
    • ・For procedures related to social insurance and its payment
    • ・To create statistics and similar materials
    • ・To communicate during emergencies
    • ・For managing information systems
  • （3）Recruitment applicants, etc.
    • ・To consider and determine employment or rejection
    • ・To send recruitment-related documents
  • （4）Other related parties
    • ・To answer or respond to inquiries, questions, etc.

4.Joint Use of Personal Data

The person responsible for the management of personal data at our company is the General Manager of the Corporate Planning Department, and we will jointly use personal data as follows.

    [Personal Data of Business Partners and Other Related Parties]
  • （1）Items of personal data to be jointly used:
    • Company name, department, position, name, address, telephone number, email address, and other information necessary to achieve the purposes listed in (3) below.
  • （2）Scope of entities jointly using the data:
    • ・MOECO and its affiliates (referring to affiliates as defined in Article 2, Paragraph 3, Item 22 of the Company Calculation Rules; hereinafter the same).
    • ・Mitsui & Co., Ltd. and its affiliates (limited to those related to our business).
  • （3）Purpose of joint use:
    • ・Collection and review of information related to the exploration, development, production, sale, and investment of oil, natural gas, and other energy resources.
    • ・Conducting meetings, providing information, and communication.
    • ・Investigations, records, and notifications to government authorities based on legal requirements.
    • ・Other matters necessary for our business management
    [Personal Data of Officers and Employees, etc.]
  • （1）Items of personal data to be jointly used:
    • ・Basic information related to the individual, such as name, address, telephone number, email address, date of birth, gender, department, position, qualifications, family structure, and photograph.
    • ・Information related to wages such as salary and retirement benefits.
    • ・Information related to attendance.
    • ・Employment history such as dates of joining and leaving the company.
    • ・Other information necessary to achieve the purposes listed in (3) below.
    （2）Scope of entities jointly using the data:
    • ・MOECO and its affiliates
    • ・Mitsui & Co., Ltd. and its affiliates (limited to those related to our business).
    （3）Purpose of joint use:
    • ・Matters related to organization and personnel (including transfers and secondments), welfare programs, safety education, and training.
    • ・Business-related communication.
    • ・Response to disasters and other emergencies.
    • ・Investigations, records, and notifications to government authorities based on legal requirements.
    • ・Management and operation of information systems.
    • ・Planning and implementation of internal and external audits.
    • ・Other matters necessary for our business management

5.Provision of personal information to a third party

MOECO shall not disclose or provide personal information to a third party without the consent of the person. However, in the following cases, personal information may be disclosed or provided to a third party as an exception:

  • （1）When required by laws and regulations
  • （2）When it is necessary to protect the life, body or property of a person and it is difficult to obtain the consent of the person.
  • （3）When outsourcing the processing of personal information after taking necessary measures to protect personal information
  • （4）When providing personal information to the entity listed in 4. (2) above for shared use of personal information

6.Safety management of personal information

MOECO shall take necessary and appropriate safety control measures for the management of personal data, to prevent personal information from being leaked, lost, or damaged. In addition, MOECO shall properly supervise employees and contractors (including subcontractors) who handle personal information. The contents of the security control measures for personal data are as follows:

  • （1）Formulation of personal information protection policy
    • ・MOECO has formulated this guideline to ensure the proper handling of personal data.
  • （2）Development of discipline regarding the handling of personal data
    • ・MOECO has established personal information protection management regulations, in which it establishes a personal information management system, and also establishes rules that regulate the acquisition, use, storage, provision, disposal, etc. of personal data.
  • （3）Organizational safety control measures
    • ・A person in charge of management regarding the handling of personal data has been appointed.
    • ・Employees who handle personal data and the range of personal data handled by the employees are clarified.
    • ・MOECO operates a reporting and communication system to the person in charge of management when an employee, etc. becomes aware of a fact or sign that violates the Personal Information Protection Law or regulations.
  • （4）Human safety control measures
    • ・Improper handling of personal data is stipulated as a disciplinary reason in the work regulations.
    • ・MOECO has stipulated in the Code of Conduct for Officers and Employees that MOECO shall strictly manage personal information, and all officers and employees have pledged to comply with this code.
  • （5）Physical safety control measures
    • ・MOECO have set areas for handling personal data and are implementing measures to prevent unauthorized persons from viewing personal data.
    • ・MOECO will take measures to prevent theft or loss of devices, electronic media and documents that handle personal data.
  • （6）Technical safety control measures
    • ・Access control is implemented to limit the scope of the person in charge and the personal information database handled.
    • ・MOECO has introduced a mechanism to protect information systems that handle personal data from unauthorized access or software from third parties.

7.Implementation of continuous improvement

MOECO has established a management system for the protection of personal information, and while implementing and maintaining the program, MOECO will make timely reviews of the program as part of our efforts for continuous improvement.

8.Compliance with laws and regulations

When handling personal information, MOECO complies with all laws and other regulations regarding the protection of personal information, as well as all governmental guidelines.

9.Request for disclosure of personal information, etc.

When there is a request for inquiries, corrections, suspension of use, erasure, etc. of personal information, MOECO shall promptly respond after confirming the identity of the person by the prescribed procedure.

Inquiries regarding personal information:

If you have any questions or complaints regarding our handling of personal data, please contact the following contact.
Otemachi One Mitsui&Co. Building 14F 2-1,
Otemachi 1-chome, Chiyoda-ku, Tokyo 100-0004, Japan
Mitsui Energy Development Co., Ltd.
Corporate Strategy and Planning Division