The fundamental information security policy of Nippon Koei Co., Ltd. is to maintain the trust placed in the Company by society, customers and business partners by ensuring the security and reliability of the information assets that it employs throughout its business activities, based on its management philosophy “To act with sincerity and contribute to society through technology.”

Nippon Koei rigorously carries out the following practices based on its management philosophy and fundamental information security policy.

• 1. Nippon Koei establishes information security management policies for each type of information asset obtained in the course of business.
• 2. All Nippon Koei staff who obtain information assets in the course of business recognize the importance of information security, strictly adhere to the fundamental information security policy and operate in compliance with the regulations on management standards and procedures that are set out in the fundamental information security policy.
• 3. Nippon Koei recognizes the importance of information assets entrusted to it in the course of business, and shall use them appropriately and prevent their leakage.
• 4. Nippon Koei complies with laws and standards concerning information security management.
• 5. Nippon Koei has established and continually works to upgrade its information security management framework in order to respond to new threats to information assets.

President
December 21, 2004