Disclosure Policy

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1. Basic policy for information disclosure

The Company is committed to improve its internal system to enable appropriate and timely disclosure of accurate and fair corporate information to its shareholders and investors bearing in mind at all times its shareholders’ and investors’ interests and sufficiently recognizing that timely and appropriate provision of corporate information to its shareholders and investors constitutes the basis of a healthy securities market. Through timely and appropriate information disclosure, the Company endeavors to establish a relationship of trust with its shareholders and investors and to provide feedback on market evaluations to its management, thereby contributing to increasing shareholder value.

2. Criteria for information disclosure

(1) Timely disclosure of important information
The Company discloses any important information in accordance with the Financial Instruments and Exchange Act and other related laws and regulations, as well as in accordance with the Timely Disclosure Rules of the Tokyo Stock Exchange, on which the Company is listed.

(2) Voluntary disclosure
For any information that does not fall under the foregoing, the Company endeavors to proactively disclose such information insofar as the information is deemed useful and contributes to investment decisions, while ensuring timeliness and fairness.

3. Method of information disclosure

The Company discloses any important information in the manner prescribed by the Timely Disclosure Rules; all other information subject to voluntary disclosure as useful but not categorized under the said Rules will be disclosed through the Timely Disclosure Network (“TDnet”) provided by the Tokyo Stock Exchange. Simultaneously therewith, all such information is posted on the Company’s website.

4. Internal system for information disclosure

Under the supervision of the Information Management Officer, who is responsible for disclosure of important information by the Company, the PR/IR group established in the Corporate Planning Division specializes in information disclosure and IR activities of the Company. The General Manager of the said Division serves as the responsible person for PR/IR activities aimed at ensuring transparency in the Company’s business activities and at gaining more credibility among all stakeholders.
The Corporate Planning Division is engaged in appropriate and prompt disclosure of all information, including those to be resolved in meetings of the board of directors. These matters are resolved after collecting information and exchanging opinions by holding meetings with the relevant divisions and affiliates of the Company and after discussions with the Information Management Officer and the person responsible for PR/IR. The Representative Director, Chairman, President and CEO, the management team, and related divisions may participate in the Company’s IR activities to receive explanations, as necessary.
The Company holds a briefing on its financial results twice a year for analysts and corporate investors in Japan. It also holds small-scale briefings hosted by a security company, with personal interviews and telephone conferences, as appropriate. For analysts and corporate investors overseas, the Company holds personal interviews and telephone conferences in addition to personal visits, as appropriate.
The Company has set up an information management system to handle any unpublished important fact (“Insider Information”) and personal information, in accordance with the Employment Rules, Insider Trading Management Regulations, Information Security Management Regulations, Personal Information Protection Regulations, and other regulations of the Company. The Company is committed to ensure fair information disclosure in its communication with the various stakeholders.

5. Silent period

The Company has set aside a certain silent period for its IR activities, a 14-day period ending on the date of announcement of its financial results, in order to prevent any leakage of Insider Information and to ensure fairness of information disclosure. During the said period, it does not make any comment or answer any question in connection with the unpublished financial results. However, if there emerges any fact that is subject to timely disclosure during the said period, the Company will disclose such information in accordance with the Timely Disclosure Rules.

6. Future outlook

Any information disclosed by the Company that does not fall under historical fact is nothing more than the Company’s outlook for the future and forecast, under a contract based on the decision of the Company at the time of disclosure. When the Company is to disclose such a forecast, it will clearly state with regard to such disclosure that the forecast is subject to risk, it may include uncertain data or other factors, and that it may vary from actual results or performances.

7. Earnings expectations by a third party

The Company does not generally comment on any assessment, earnings expectations, or rumors made by a third party regarding the Company. However, this will not apply in cases where the Company determines that such information causes, or is likely to (a) cause significant damage to the interest of its shareholders or the corporate value of the Company, (b) lead to misinterpretation in the capital market, or (c) create a necessity for an explanation or action as requested by the listed securities market or any other agency.