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Shareholder Personal Information Protection Policy

Nippon Telegraph and Telephone Corporation (NTT)

NTT will handle the personal information of the Shareholder ("Shareholder Personal Information"; such information excludes the individual numbers and specific personal information of the Shareholder) in accordance with the following policy, on the basis of the "NTT Group Information Security Policy". In this policy, "Shareholder" means a shareholder or registered pledgee of shares (touroku kabushiki shichikensha), or a statutory agent of them, who are listed or recorded in the shareholders' register as an individual, rather than legal entity.

1. Handling of Shareholder Personal Information

  1. The Purposes of Use of Shareholder Personal Information
    The purposes of use of Shareholder Personal Information retained by NTT are as follows.

    A.To exercise the rights and perform the obligations under the Companies Act.

    B.To provide various facilities to the Shareholder in accordance with his/her position as a shareholder, etc.

    C.To take various measures in order to smooth the relationship between the Shareholders and NTT, in terms of the members of the association and the association itself.

    D.To conduct the shareholders management such as preparing data of the Shareholders which satisfies certain criteria prescribed in applicable laws.

    Further, when collecting Shareholder Personal Information stated in a written document directly from the Shareholder (including through electronic records), NTT will explicitly indicate the purposes of use to such Shareholder except in cases falling under any of the items of Article 21, Paragraph 4 of the Act on the Protection of Personal Information.
    Moreover, in cases falling under Article 18, Paragraph 3 of the Act on the Protection of Personal Information, Shareholder Personal Information may be handled beyond the extent necessary to achieve the abovementioned purposes of use.

  2. Provision of Shareholder Personal Information to Third Parties
    Except in the case where Shareholder Personal Information is provided to third parties in accordance with any of the items under Article 27, Paragraph 1 or Paragraph 5 (excluding Item 3) of the Act on the Protection of Personal Information, NTT will not provide Shareholder Personal Information to any third parties without obtaining prior consent of the Shareholder.
  3. Joint Use of Shareholder Personal Information
    NTT will not jointly use Shareholder Personal Information with any third parties.
  4. Disclosure and other Procedures in Regard to Shareholder Personal Information Retained by NTT
    NTT will respond to requests for disclosure, correction, addition, deletion, suspension of usage, or disposal of Shareholder Personal Information retained by NTT, requests for disclosure of Shareholder Personal Information retained by NTT provided to third parties and requests for suspending the provision of Shareholder Personal Information retained by NTT to third parties, in each case, in accordance with the Act on the Protection of Personal Information.

    A.Documents Required for Requests for Disclosure etc.
    When making a request for disclosure etc., please download and mail or bring the following request forms to NTT, attaching required documents to such request form.

    (Processing fees of 1,000 yen (consumption tax included) will be charged for each disclosure request. When mailing, please send the request form and the processing fee by currency registration.)

    Please note that the foregoing shall not be applicable when making a request for disclosure in accordance with laws other than the Act on the Protection of Personal Information, such as the Companies Act.
    Moreover, NTT will not make correction etc. or make suspension of the usage etc. of Shareholder Personal Information which is described or recorded on shareholders' register, except in cases where the Shareholder transfers NTT's shares to third parties and NTT describes or records such transfer on the shareholders' registry pursuant to the provisions of laws such as the Companies Act.

    *Regarding the proceedings for transferring NTT's shares of the Shareholders, or for making descriptions or records of such transfer on the shareholders' register, please contact your securities company or Sumitomo Mitsui Trust Bank, the administrator of NTT's shareholders' register.

    B.Address to Send Request Forms:
    Nippon Telegraph and Telephone Corporation, Point of Contact for Shareholder Personal Information
    5-1, Otemachi 1-Chome
    Chiyoda-ku, Tokyo 100-8116, Japan.
    Email: kabunushisama-info@ntt.com

    *Concerning the handling of Shareholder Personal Information obtained by a "Request for Disclosure etc." The purpose of use of Shareholder Personal Information obtained by a request for disclosure etc. shall be limited to the extent necessary for dealing with such request for disclosure etc.

  5. Point of Contact for Consultation Regarding Shareholder Personal Information
    The point of contact for consultation regarding the handling of Shareholder Personal Information can be reached by mail or email at the address/email address as stated below. We are afraid that we are unable to accommodate in-person inquiries. Thank you for your understanding.

    Nippon Telegraph and Telephone Corporation, Point of Contact for Shareholder Personal Information
    5-1, Otemachi 1-Chome
    Chiyoda-ku, Tokyo100-8116, Japan.
    Email: kabunushisama-info@ntt.com

2. Compliance with Laws

When handling Shareholder Personal Information, NTT will comply with the "Act on the Protection of Personal Information", relevant laws and regulations, and applicable guidelines published by competent ministries and industry associations.

3. Security Control Measures

When handling Shareholder Personal Information, NTT will take appropriate organizational security control measures, personnel-related security control measures, physical security control measures, technological security control measures and assessments of the external environment.

  1. Organizational Security Control Measures
    NTT (a) constructs committees, appoints managers of each organization, and constructs other organizational management systems, (b) establishes internal rules, (c) prepares statements including management ledgers and process management tables, and (d) improves the foregoing continuously.
  2. Personnel-Related Security Control Measures
    NTT (a) informs and educates all employees who handle Shareholder Personal Information as to the significance of the protection of Shareholder Personal Information, regardless of whether such employees are officers, full-time employees, or dispatched employees, (b) enters into non-disclosure agreements with such employees, and (c) conducts necessary oversight and supervision, in order to ensure effectiveness of personnel-related security control measures. In addition, when commissioning work with respect to the handling of Shareholder Personal Information, NTT will monitor whether the commissioned parties (including any subcontractors and other parties) are appropriately managing Shareholder Personal Information, and, in the event that improvements are necessary, will promptly make requests for improvement. If no improvements are observed thereafter, NTT will take strict actions accordingly, including the replacement of the commissioned parties and other necessary measures.
  3. Physical Security Control Measures
    NTT takes physical security control measures such as (a) access controls and theft preventions etc. for buildings and floors where Shareholder Personal Information is handled, (b) measures against damage to Shareholder Personal Information caused by fire, lightning, etc. and (c) locking management when removing, transferring or storing systems and documents.
  4. Technological Security Control Measures
    NTT takes technological security control measures such as (a) access controls, including authentication, authority management, controls and record-keeping when accessing personal data, (b) measures to be taken for systems against unauthorized software and virus, (c) protection measures during transfer, transmission and receipt by means of encryption, clarification of responsibilities or the like and (d) monitoring of information systems.
  5. Assessments of the External Environment
    When handling Shareholder Personal Information outside of Japan, NTT will conduct assessments of the relevant systems regarding the protection of such personal information, and will take measures to ensure the safe management of Shareholder Personal Information accordingly.

4. Continuous Improvement of Management Systems

NTT will be proactive in the protection of Shareholder Personal Information by regularly, continuously and flexibly reviewing management systems and rules, and making constant improvements to ensure timely and appropriate management systems aligning with changing technologies and legal systems.

5. Anonymously Processed Information

NTT may create anonymously processed information based on Shareholder Personal Information and provide such information to third parties. In such cases, NTT will disclose the following items to the public on the homepage etc.

A.Items of information concerning an individual that are included in the anonymously processed information created by NTT;

B.Items of information concerning an individual that are included in the anonymously processed information to be provided to third parties;

C.Methods of providing anonymously processed information to third parties; and

D.Particulars of security control measures adopted.

When handling anonymously processed information, NTT will take the security control measures as stated in No.3 above. Further, NTT will provide necessary and appropriate supervision of employees and outsourcing contractors (including subcontractors etc. of such outsourcing contractors) who handle anonymously processed information.