Disclosure Policy

(1)Standards for information disclosure

Our company provides timely disclosure of information based on principles of transparency, fairness and continuity. This is done in accordance with relevant laws and regulations such as the Financial Instruments and Exchange Act. We also comply with the listing rules established by the Tokyo Stock Exchange for “Timely Disclosure of Company Information, Etc.” (hereinafter referred to as the “Timely Disclosure Rules”). Even in circumstances where the Timely Disclosure Rules and relevant laws or regulations do not apply, we will proactively and fairly disclose information that we deem to be important or useful for shareholders and investors in understanding our company.
We will not disclose personal information, customer information or information that infringes the rights of related parties.

(2)Method of disclosure

Disclosure of information stipulated by the Timely Disclosure Rules will be done in accordance with those rules through the Company Announcements Disclosure Service (TDnet) provided by the Tokyo Stock Exchange. After disclosure on TDnet, the information will promptly be posted on our website. Information that does not fall under the Timely Disclosure Rules, but that we deem to be important or useful, will be widely disclosed by posting it on our website, etc.

(3)Prevention of insider trading

We have established rules for information management and insider trading management to prevent insider trading. In addition, every year, we hold study sessions on insider trading regulations for officers and employees and distribute informational materials as part of our efforts to raise awareness and understanding of insider trading. We also draw attention to the issue of insider trading through internal notifications when appropriate.

(4)Handling of earnings forecasts and future information

When our company discloses earnings forecasts, predictions for the future, strategies, goals or similar information, and that information does not concern past or present facts, it constitutes a forward-looking statement. Such statements are based on information we currently have, as well as plans, expectations and judgments grounded in certain assumptions that we deem reasonable. Accordingly, earnings forecasts and similar information may differ from actual earnings, etc. due to economic conditions and other uncertainties.

(5)Slient Period

Our company has established a quiet period to prevent leaks of information on financial results (including quarterly financial results) and ensure the fairness of information disclosure. This quiet period runs from the day after the end of the settlement of accounts (quarterly settlement) to the date of the announcement of those results. During this period, we will refrain from answering or commenting on questions regarding our financial results or earnings forecast. However, if our earnings forecast is expected to fluctuate significantly during this period, it will be announced as appropriate in accordance with the Timely Disclosure Rules.

(6)Maintenance of internal systems

On the basis of this disclosure policy, our company strives to maintain and enhance our internal systems for disclosing information as appropriate in accordance with applicable laws and regulations and the Timely Disclosure Rules.