Information security policy

1.Purpose

A.D.A.M. Innovations Co. (hereinafter, the "Company") utilizes a wide range of information assets in conducting its business and managing its employees (hereinafter, the "Business"). The Company recognizes that appropriately ensuring information security and protecting its information assets is not only an essential requirement for conducting corporate activities based on public trust, but also a significant social responsibility. Accordingly, in view of the importance of information security, the Company has established this Information Security Policy (hereinafter, this "Policy"), and will establish, implement, maintain and continually improve an information security management system (ISMS) to put this Policy into practice.

 

2.Commitments

In accordance with this Policy and the Company's ISMS, the Company will carry out the following:

1. Information Security Objectives
   The Company will establish information security objectives that are consistent with this Policy and take into account applicable information security requirements and the results of risk assessment and risk treatment. These objectives will be communicated to all employees and reviewed as needed in response to changes in the Company's environment, and periodically even when no changes occur.

2. Handling of Information Assets

   • Access rights will be granted only to those who require them to perform their duties.

   • Information assets will be managed in accordance with legal, regulatory and contractual requirements and the provisions of the Company's ISMS.

   • Information assets will be appropriately classified and managed according to their importance, based on their value and from the perspectives of confidentiality, integrity and availability.

   1. Information assets will be continuously monitored to confirm that they are properly managed.

3. Risk Assessment

   • The Company will conduct risk assessments, and will implement appropriate risk treatment and introduce controls for the information assets deemed most important in light of the nature of the Business.

   • The Company will analyze the causes of information security incidents and take measures to prevent their recurrence.

4. Business Continuity Management
   The Company will minimize business disruptions caused by disasters, failures and other events, and ensure its ability to continue its business.

5. Education and Training
   The Company will provide information security education and training to all employees.

6. Compliance with Rules and Procedures
   The Company will comply with the rules and procedures of its ISMS.

7. Compliance with Legal, Regulatory and Contractual Requirements
   The Company will comply with legal, regulatory and contractual requirements related to information security.

8. Continual Improvement
   The Company will strive for the continual improvement of its ISMS.

 

3.Responsibilities, Obligations and Penalties

The Representative Director is responsible for the ISMS, including this Policy, and all employees within the scope of the ISMS are obliged to comply with the established rules and procedures. Any employee who fails to fulfill these obligations or commits a violation will be subject to disciplinary action in accordance with the Rules of Employment. Personnel of partner companies will be handled in accordance with individually agreed contracts or other arrangements.

 

4.Periodic Review

The ISMS will be reviewed periodically and as necessary, and will be maintained and managed accordingly.



 

Established: August 1, 2026

Last revised: September 17, 2026

Michel Mommejat, Representative Director