Information Security Policy

ABCD inc. (the “Company”) works toward a vision of removing every point of friction in international trade, and of building a foundation and a marketplace on which anyone in the world can trade with confidence. Through the world’s first compound product that turns international trade transactions into credit assets, we remove that friction and bring every task leading up to the completion of a deal together around one Deal ID. Transactions become credit, the cost and terms of trade are optimised, and new opportunities are created. Contributing to the development of international trade in this way is our corporate mission.

In carrying out this mission, the Company recognises that protecting the information assets entrusted to us by our customers, business partners and partner companies, together with the information assets we hold ourselves, from accidents, disasters, crime, cyberattacks and every other threat is both the foundation of our business continuity and a social responsibility.

The Company establishes and operates an Information Security Management System (ISMS), and maintains and improves the confidentiality, integrity and availability of information assets, so as to merit the trust placed in us by our customers and by society.

Guiding Principles

1. Responsibility of Management

Management personally provides leadership, recognises the importance of information security, and works to improve and strengthen it in an organised and continuous manner. Management secures the resources information security requires and is accountable for its effectiveness.

2. Organisational Structure

To maintain and continuously improve information security, the Company establishes an Information Security Committee and sets out information security measures as formal internal regulations. An information security officer is appointed in each division, forming a structure that spans the whole company.

3. Protection of Information Assets

The Company assesses the importance of every information asset it holds and applies appropriate controls based on risk assessment. We secure the confidentiality, integrity and availability of information assets and protect them from unauthorised access, leakage, alteration, loss, destruction and other threats.

4. Compliance with Laws and Regulations

The Company complies with the laws, regulations, contractual obligations and other social norms that relate to information security. As a business engaged in international trade, we also respond appropriately to the relevant laws and regulations of each country and region.

5. Commitment of Our People

The Company’s officers and employees understand the importance of information security and receive continuous education and training to acquire the knowledge and skills it requires. All officers and employees observe the information security measures that have been established and work to keep information secure.

6. Incident Response

The Company maintains a structure for responding promptly and appropriately to information security incidents. Should an incident occur, we work to minimise the damage and prevent it from spreading, and we see through the investigation of its cause and the implementation of measures to prevent recurrence.

7. Business Continuity

The Company prepares a business continuity plan and takes the necessary measures so that critical business activities can be continued, or restored quickly, even in the event of a disaster, a system failure or another emergency.

8. Continual Improvement

The Company evaluates and reviews the effectiveness of its Information Security Management System on a regular basis and pursues continual improvement through the PDCA cycle. We respond to changes in the social environment and in technology, and to new threats, and continue to seek the most appropriate information security measures.

This policy applies to all officers and employees of the Company and to everyone who handles the Company’s information assets. The Company also makes this policy available to interested parties, including by publishing it on the Company’s website.

Established: January 30, 2026
ABCD inc.
Tatsuya Shiono, Representative Director and CEO