Disclosure Policy

Basic Policy

1. The Company will strive to provide information, such as the Group’s management strategies, business activities, financial standing, governance, sustainability, risks, etc., promptly to all stakeholders including shareholders and investors, while ensuring transparency, fairness, and continuity in disclosing information. The aim is to enable all stakeholders to properly understand the Purpose, which defines the Group’s identity; the Business Philosophy, which defines the Group’s action guidelines; management strategies; and business activities, etc. in order to receive a fair evaluation of our corporate value and earn the trust from them.

   
   

2. The Company will make timely disclosure via TDnet in accordance with timely disclosure rules established by financial instruments exchanges, and will promptly disclose this information on its website. Furthermore, will also actively disclose information that we consider useful for all stakeholders to understand our Group.

   
   

3. To prevent leakage of financial results information and thereby ensure fairness, we set a certain period from the announcement of financial results to about one month before as a quiet period when we refrain from answering questions and commenting regarding financial results. However, in the event of an expectation arising that significantly differs from the performance forecast during the quiet period, information shall be disclosed at the appropriate time and in the appropriate manner, in accordance with the timely disclosure rules, etc.

   
   

4. From the viewpoint of fairness, we will work to disclose information in English.

*Note

• Any posting on the website of the Company that is not a historical fact is a statement of forecasts made by the Company based on information that was available when it was published. These forward-looking statements include known and unknown risks, uncertainties and other factors. Actual results may prove to be different from these forecasts.

  
  

• Although the Company strives to ensure the accuracy of information published on its website with the greatest possible care, the Company shall not be held liable for any damage arising from an error in the published information or a failure during the browsing and downloading of information.

  
  

• The information published on the website of the Company is intended for the purpose of providing information and not for the purpose of investment solicitation. The readers of the website of the Company are asked to make investment decisions based on their own judgment and at their own responsibility.

Basic Policy on Dialogue with Shareholders

1. The Company, through the thorough performance of fair information disclosures (fair disclosures) and ongoing dialogue with domestic and overseas shareholders, shall construct a relationship of trust with shareholders and reduce information asymmetry.
   

   
   

2. The Company, for constructive dialogue with shareholders, shall endeavor to ascertain the shareholder structure, and will pay close attention to any possibility of a leakage of insider information in having such dialogue.

   
   

3. The Company shall designate the Representative Executive Officer & Co- President, the General Manager of the Investor Relations Department, and the General Manager of the General Affairs Department as contact points for dialogue with shareholders, and also shall arrange for opportunities for dialogue with Outside Directors of the Board.

   
   

4. The Company shall provide appropriate feedback to the Board of Directors on the opinions of shareholders obtained in the course of the dialogue as appropriate to reflect them in management, and will utilize the opinions of Directors of the Board, including Outside Directors of the Board, in dialogue with shareholders.

Information Disclosures and Dialogue Subject to the IR Policy

1.Statutory Disclosures

（1）Disclosures in Accordance with the Financial Instruments and Exchange Act Securities registration statement, annual securities reports, quarterly reports, extraordinary reports, etc.

（2）Disclosures in Accordance with the Companies Act

Notice of General Meeting of Shareholders, business reports, financial statements, consolidated financial statements, etc.

2.Disclosures Required by the Financial Instruments Exchange

（1）Timely Disclosure

Disclosures of information about corporate decisions and events occurred and financial information, etc. required by the Tokyo Stock Exchange

（2）Corporate Governance

Response to the Corporate Governance Code and Corporate Governance Report required by the Tokyo Stock Exchange

3. Other Information Disclosures

（1）Presentation materials/videos

（2）Integrated reports

（3）Shareholder newsletters

（4）Investor Relations (IR website)

（5）Daily dialogue with analysts and institutional investors, etc.

Timely Disclosure Structure

1. We are working to enhance and strengthen corporate governance to realize fair and highly transparent management. In particular, the Company regards speedy and accurate disclosure to investors in compliance with the provisions of the Financial Instruments and Exchange Act and other applicable laws and regulations and timely disclosure rules prescribed by financial instruments exchanges as an important management role and has adopted the following internal system.

   
   

2. Information on financial results will be reported to the Board of Directors after these results are finalized by the Finance & Accounting Department and audited by the accounting auditor, and they are then disclosed as a summary of accounts on the day of approval. Regarding revisions of financial forecasts, the Representative Executive Officer & Co-President receive regular reports on the earnings outlook from the Finance & Accounting Department, monitor any changes in the expected financial performance of the Group due to changes in the business environment and deliberate on measures to respond to such changes. Based on the results, the Board of Directors reports and deliberates whether the announced earnings forecast should be revised.

   
   

3. Information on the decision is promptly disclosed in accordance with timely disclosure rules after the decision is made by an appropriate decision making authority such as the Board of Directors.

   
   

4. Regarding information on the occurrence of such, the officer in charge of the head office collects and promptly discloses all information in accordance with timely disclosure rules, and also voluntarily discloses certain other important facts.

   
   

5. Information on subsidiaries is specified in the internal rules as a matter that the officer in charge should report to the Company, and since matters of high importance require approval by the Board of Directors of the Company, they are disclosed in accordance with timely disclosure rules through deliberation.

   
   

6. The general affairs department manager has been appointed as the insider trading information manager. Handling of information subject to insider trading regulations is stipulated in the Insider Trading Prevention Rules, and the insider trading information manager manages the operation thereof (See the chart below.)

   
   

7. After registering with TDnet, the Investor Relations Department and the Public Relations Department will handle any inquiries regarding disclosure information. The Company strives to provide opportunities for investors, etc., to have fair and easy access to information. For example, the Company publishes the same information in the website of the Company promptly after it is disclosed to the financial instruments exchange.

   
   

Structure to Prevent Insider Trading

Structure to Promote Information Disclosures and Dialogue

The Company, through the partnership of the Representative Executive Officer & Co-President, management team, and the general managers of the departments set forth below, shall engage in investor relations activities, shareholder relations activities, statutory disclosures, timely disclosures, disclosure of important decisions.

• Investor Relations Department
• Public Relations Department
• Finance & Accounting Department
• Corporate Governance Department
• Other Related Departments

Major Initiatives to Promote Dialogue with Shareholders