TKK International

Conflict of Interest Agreement

Confidentiality and Conflict of Interest Agreement

T.K.K. International Co., Ltd. recognizes the critical importance of protecting the privacy of individuals and securing the confidentiality of all company records. Employees and Contractors of T.K.K. International Co., Ltd. will make appropriate efforts to protect and secure company data and information.

Every position that frequently has privileged access to computing systems, applications, databases, network monitoring tools, and other equipment that may contain records and information that are private and confidential in nature. As an employee of T.K.K. International Co., Ltd., I may be entrusted with such privileged access and encounter or have access to sensitive, confidential, or proprietary information whether or not it is labeled or identified as such.

I acknowledge the sensitive and confidential nature of information concerning T.K.K. International Co., Ltd. employees, customers, clients, vendors, and other members of T.K.K. International Co., Ltd. community. I understand and agree that this information may only be disclosed with proper authorization and in the exercise of my designated duties.

I agree not to use any access or information available to me in the course of my duties to engage in any activity that conflicts with the interests of T.K.K. International Co., Ltd. or use any access available to me to provide information to others engaged in any activity that conflicts with the interests of T.K.K. International Co., Ltd.

Specifically, with respect to company computing systems, customer data, networks, records, files, email, and other information, I agree that I will treat all confidential information as such by respecting the privacy of users, the integrity of the systems, and the related physical resources, and I will:

1. Access, copy, or store data solely in the performance of my job responsibilities, limiting perusal of contents and actions taken to the least necessary to accomplish the task.

2. When providing direct services to users, copy or store data or information only with the user’s consent and only to complete a specified task, and only to copy and store user data for long enough to complete the specified task.

3. Not seek personal benefit or permit others to benefit personally from any data or information that has come to me through my work assignments.

4. Not make or permit unauthorized use of any information in the company’s information systems or records.

5. Not enter, change, delete or add data to any information system or file outside of the scope of my job responsibilities.

6. Not intentionally or knowingly include or cause to be included in any record or report, a false, inaccurate or misleading entry.

7. Not intentionally or knowingly alter or delete or cause to be altered or deleted from any records, report or information system, a true and correct entry.

8. Not release company data other than what is required for the completion of my job responsibilities.

9. Not exhibit or divulge the contents of any record, file, or information system to any person except as required for the completion of my job responsibilities.

10. Take every reasonable precaution to prevent unauthorized access to any passwords, user identifications, or other information that may be used to access company information systems or records.

11. Limit access to the information contained in or obtained from the systems to authorized persons.

12. Report any incidents of my non-compliance with the terms of this agreement to my Supervisor.

I further agree that while employed by T.K.K. International Co., Ltd., I will not directly or indirectly engage in or have any interest, financial or otherwise, in any other business, consulting, or freelance work that may interfere with my ability to exercise judgment in the best interests of T.K.K. International Co., Ltd., or to use company time or resources in the delivery of privately contracted services.

I understand and agree that my failure to comply with the terms of this agreement will have consequences and may result in disciplinary action up to immediate termination and criminal prosecution, depending upon the infraction’s severity, evidence of my intentions, and the sensitivity and scope of the information compromised.

By signing and dating this agreement, I certify that I have read this agreement, that I agree to its terms, and that the agreement remains in effect continuously for the duration of my employment by T.K.K. International Co., Ltd. I also agree that when my employment with T.K.K. International Co., Ltd. ends, I will not keep in my possession, recreate or deliver to anyone else, any confidential, sensitive, or proprietary information whether or not it is labeled as such that I acquired while employed by T.K.K. International Co., Ltd.

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