SUSTAINABILITY FOR THE MEDIA DO GROUPBASIC INFORMATION SECURITY POLICY

The MEDIA DO Group (hereinafter "the Group") believes that it is essential to establish systems that can be used safely and securely by all stakeholders, including creators, publishers, bookstores and eBook retailers, and users (readers), in order to achieve the digital distribution of written works and build and realize a sound cycle of literary creation. In light of the increasing sophistication and complexity of cyberattacks, growing supply chain risks, and strengthened legal and regulatory requirements in recent years, the Group regards ensuring information security as one of its most important management priorities. We position information security as a critical issue directly linked to business continuity and the maintenance and enhancement of corporate value, which the Group must address.
Based on this recognition, the Group shall continuously identify and assess the changing threat environment and business risks and make reasonable, risk-based decisions. At the same time, the Group shall establish the Basic Information Security Policy to protect all information assets from threats such as unauthorized access, crime, negligence, and natural disasters.
The establishment, revision, or abolition of this policy shall be made by a resolution of the Board of Directors.

1.Establishment of an Information Security Management System

The Group shall clarify responsibilities and authorities relating to information security and establish an organization-wide management system under the involvement of management. The Group shall also develop processes for risk assessment, planning and implementation of measures, audits of implementation status, and reporting, and shall strive to ensure, maintain, and enhance their effectiveness.

2.Risk Assessment and Informed Decision-Making

The Group shall regularly identify, analyze, and assess information security risks in light of the business environment, threat trends, technological changes, and legal and contractual requirements.
The results of risk assessments shall be reported to management and utilized in decision-making regarding acceptable levels of risk, the prioritization of measures, and the allocation of resources. Important risks shall be continuously monitored.

3.Compliance with Laws, Regulations, and Internal Rules

The Group shall comply with laws and government guidelines relating to information security and establish relevant internal rules. All officers and employees, and other applicable personnel, shall be required to comply with these laws, guidelines, and internal rules, and compliance shall be reviewed regularly.

4.Information Security Education

The Group shall foster a corporate culture in which all officers and employees, and other applicable personnel, recognize their responsibilities for information security in their respective duties and act proactively. To this end, the Group shall conduct continuous education and awareness-raising activities and embed information security practices as part of its organizational culture.

5.Safeguarding of Information Assets

The Group shall implement appropriate security measures to safeguard all information assets in its possession, including personal information and information assets entrusted to it by external stakeholders such as publishers and bookstores, and eBook retailers, against threats including natural disasters, unauthorized access, loss, damage, leakage, alteration, theft, and disruption of use.
In addition, the Group shall maintain a continuous management system for its systems and networks in order to detect and identify anomalies such as cyberattacks and unauthorized access at an early stage.

6.Response to Incidents

The Group shall strive to prevent information security incidents from occurring and establish a system that enables incidents to be reported and addressed promptly and appropriately when they occur.
In the event of an incident, the Group shall identify the cause, assess the impact, implement corrective measures and measures to prevent recurrence, and promptly report the results to management. The Group shall also strive to minimize damage and restore affected systems and operations promptly and appropriately. Where necessary, the Group shall respond appropriately to relevant authorities and stakeholders.

7. Review and Improvement

The Group shall continuously review and improve its activities under each of the above items.

Established on October 13, 2021
Revised on September 1, 2026

Yasushi Fujita

President and CEO