Security Policy :-

LeadCap Consulting. ("LeadCap"), a consulting firm providing comprehensive consulting services, provides various services by utilizing LeadCap's intellectual property based on confidential information disclosed to LeadCap by its clients.

Although LeadCap has consistently implemented business ethics as a professional in its business conduct and has been striving for the establishment of an information management framework, LeadCap has recognized the need to expressly reiterate its understanding that information security is one of the most important issues concerning the management and the business operation of LeadCap.

LeadCap therefore establishes a basic policy on information security (the "Information Security Policy") and will appropriately protect all information assets that LeadCap deals with by ensuring that LeadCap's directors, officers and employees abide by the Information Security Policy set out below.

1. Establishment of Information Security Management System ("ISMS")
LeadCap ensures that all directors, officers and employees understand the importance of information security. LeadCap establishes ISMS to ensure appropriate management of information assets and continuously seeks to improve ISMS.

2. Legal and Regulatory Compliance
LeadCap ensures that its framework for information security is in compliance and conformity with the relevant local laws, regulations and other various standards. LeadCap also fully complies with the spirit of those laws, regulations and other various standards.

3. Information Assets Protection
To appropriately protect information assets of LeadCap and LeadCap's clients from threats to confidentiality, integrity and availability of such information assets and to ensure the continuity of LeadCap's business, LeadCap formulates appropriate management plans for information assets of LeadCap and LeadCap's clients for not only LeadCap's each department and subsidiaries, but also LeadCap's business partners, having regard to their business activities and the form of their business.

4. Education and Training
LeadCap will continuously train and educate its directors, officers and employees to raise their awareness of information security and implement an information security system in all of its business activities.

5. Incident Response
LeadCap implements appropriate measures to prevent incidents relating to information security. In the event that such incidents occur, not only LeadCap promptly deals with such incidents, but also takes steps to prevent the recurrence of similar incidents.