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Sample Template for XXX Co., Ltd. Procedures for Handling Material Inside Information  CH

Announced Date: 2008.11.12 
Categories: Corporate Governance
   Chapter II Procedures for Maintaining Confidentiality of Material Inside Information
Article 6    (Confidentiality firewall operations - Personnel)
    This Corporation's directors, supervisors, managerial officers, and employees shall exercise the due care and fiduciary duty of a good administrator and act in good faith when performing their duties, and shall sign confidentiality agreements.
    No director, supervisor, managerial officer, or employee with knowledge of material inside information of this Corporation may divulge the information to others.
    No director, supervisor, managerial officer, or employee of this Corporation may inquire about or collect any non-public material inside information of this Corporation not related to their individual duties from a person with knowledge of such information, nor may they disclose to others any non-public material inside information of this Corporation of which they become aware for reasons other than the performance of their duties.
Article 7    (Confidentiality firewall operations - Documents and information)
    Proper protection of confidentiality shall be given to files and documents containing this Corporation's material inside information when transmitted in written form. When transmitted by e-mail or other electronic means, such files and documents must be processed with appropriate security technology such as encryption or electronic signatures.
    Files and documents containing this Corporation's material inside information shall be backed up and stored in a secure location.
Article 8    (Operation of confidentiality firewalls)
    This Corporation shall ensure that the firewalls specified in the preceding two articles are established, and take the following additional steps:
  1. Adopt adequate control measures for the firewalls and perform periodic testing.
  2. Enhance measures for custody and maintaining the secrecy of files and documents containing non-public material inside information of this Corporation.
Info
Article 9    (Confidentiality obligations of outside organizations and persons)
    Any organization or person outside of this Corporation that is involved in any corporate action of this Corporation relating to a merger or acquisition, major memorandum of understanding, strategic alliance, other business partnership plans, or the signing of a major contract shall be required to sign a confidentiality agreement, and may not disclose to another party any material inside information of this Corporation's thus acquired.