Information Security Basic Policy

As an investment advisory firm, investment management firm, and Type II Financial Instruments Business Operator, Strategic Capital, Inc. (the “Company”), recognizes that ensuring information security through the appropriate protection and management of information assets is one of our most important management priorities. Accordingly, the Company has established this Information Security Basic Policy, and we will further strengthen information security measures.

（1）Scope

This Policy applies to all directors and employees of the Company, including dispatched workers and part-time employees (collectively, STAFF).

（2）Structure and Role

The Company appoints an Information Security Officer (“ISO”) to oversee information security initiatives.
The ISO shall promote the secure handling of information assets as defined below, monitor compliance with laws and regulations, and implement education and training.

（3）Protection of Information Assets

STAFF shall exercise strict care in handling information assets in accordance with the separately established Information Security Management Manual.

（4）Compliance with Laws and Regulations

The Company shall comply with the Act on the Protection of Personal Information and all other laws, regulations, and guidelines related to information security.

（5）Education and Training

The Company shall regularly conduct the necessary education and training to ensure that all STAFF fully recognize the importance of information security.

（6）Continuous Improvement

The Company shall periodically evaluate and review this Information Security Basic Policy and the Information Security Management Manual and seek the continuous improvement of its information security management.