Disclosure Policy

Establishment: March 23, 2018
Effective on : April 1, 2018
Amendment : December 10, 2021

1. Basic Policy

We disclose information in a timely and appropriate manner in accordance with laws and regulations and respect the purpose and significance of the Tokyo Stock Exchange "Corporate Governance Code" and the Financial Instruments and Exchange Act "Fair Disclosure Rules" (hereinafter referred to as the "FD Rules"). By actively and fairly conducting IR activities, we will promote constructive dialogue with shareholders and investors, and enhance corporate value and the common interests of shareholders over the medium- to long-term.

2. Information Disclosure Means

This policy covers information disclosure and dialogue by the following means.

(1) Statutory disclosure

(1) Disclosure under the Financial Instruments and Exchange Act
Securities reports, quarterly reports, internal control reports, extraordinary reports, etc.
(2) Disclosure under Company Law
Business reports, financial statements, consolidated financial statements, etc.

(2) Disclosure required by Tokyo Stock Exchange

(1) Timely disclosure (decision facts, occurrence facts, financial Information, etc.), financial results, quarterly financial results
(2) Corporate Governance Report

(3) Other information disclosure

(1) IR related disclosure materials (results briefing materials, etc.)
(2) Dialogue, such as meetings with analysts and institutional investors, briefing sessions for individual investors, etc.
(3) Our website, General Meeting of Shareholders notices, shareholder communications, Corporate Report, etc.

3. Information disclosure system

The "Information Disclosure Team" consisting of the Representative (President), the Information Handling Officer (CFO or Head of department in charge of IR), the Timely Information Disclosure Officer (Public Relations Department Manager), and the Securities Report, etc. Representative (Accounting Department Manager) will deliberate and make decisions concerning the disclosure of company information, and deliberate and report at the Board of Directors as appropriate. Also, the Auditors and Accounting Auditors will conduct periodic audits and provide advice and guidance. When deliberations and decision-making, etc. are required, the Company will receive advice and guidance from lawyers and other external experts as necessary.

Outline of Information Disclosure System

4. Management of important information (partial excerpt)

(1) Target information

The Company manages "Important facts in regulating insider trading" and "Numerical values related to definite financial information before publication" (hereinafter referred to as "important information") based on the FD Rules.

For other information, the Information Disclosure Team judges each case individually based on the FD Rules Guidelines, etc.

(2) Management

The Company will not convey important information to third parties until it is publicly announced. The Company will communicate with its executives and employees to the minimum extent necessary to carry out their duties and operations, and will take all possible measures to ensure the proper handling of information.

In addition, in light of the FD Rules, when the Company's executives or employees, as part of their duties, convey (or have conveyed) important information to business related persons of financial instrument business operators, etc. (hereinafter referred to as "Business Related Persons") as specified in the FD Rules, we will take appropriate measures such as public announcement.

5. Basic Policy on Information Disclosure and Dialogue with Shareholders / Investors

The Company shall set the following basic policy regarding disclosure of information and dialogue with shareholders and investors, etc. (hereinafter referred to as "Dialogue").

(1) Compliance with related laws and regulations

The Company will comply with relevant regulations such as the Financial Instruments and Exchange Act, the Company Law and the rules of stock exchanges.

(2) Ensuring timeliness, appropriateness, and fairness, etc.

In the event that information to be disclosed is known, we will disclose it making efforts to ensure timeliness, legality, accuracy and fairness.

Also, based on the purpose and meaning of the Corporate Governance Code and FD Rules, the Company will also actively disclose or make public information that does not fall under the timely disclosure criteria specified by the Tokyo Stock Exchange but that the Information Disclosure Team judges to contribute to investors' judgment.

(3) Dialogue

The person responsible for information handling shall be responsible for Dialogue, and the senior management, directors including outside directors, or audit & supervisory board members will make efforts to respond within the reasonable extent, and at the same time, information sharing to senior management shall be carried out as appropriate on opinions and the like obtained through Dialogue.

The person responsible for information handling will oversee the Public Relations Department in charge of Dialogue, the Public Relations Department will closely cooperate with internal related departments and promote Dialogue through the opportunities described below.

Main Opportunities Content
Briefing sessions on financial results, management plans, business forecasts, etc. Executed twice a year according to the briefing format
(Full-year: May, Second quarter: November)
Meetings for analysts and institutional investors Executed as appropriate
(individual interviews, small meetings)
IR activities for individual investors Executed as appropriate
Posting IR documentation on the website Post: Financial results information, financial results briefing materials, timely disclosure materials, securities reports, quarterly reports, notices of convocation of ordinary general meeting of shareholders, shareholders' communications, corporate reports, etc.

6. Information disclosure method

Disclosure based on the Financial Instruments and Exchange Act is conducted through the Electronic Disclosure for Investors' NETwork (EDINET) operated by the Financial Services Agency. Disclosure based on the securities listing regulations stipulated by the Tokyo Stock Exchange is conducted through the "Timely Disclosure Network (TDnet)" operated by TSE. And in principle, the information disclosed on these systems will also be posted on the Company's website. Regarding the publication of important information based on the Financial Instruments and Exchange Act, it will be performed according to the methods prescribed by the Electronic Disclosure for Investors' NETwork (EDINET) and the Timely Disclosure Network (TDnet), and by posting on the Company website.

In addition, disclosure of information other than information disclosed or announced based on the Financial Instruments and Exchange Act or the securities listing regulations stipulated by the Tokyo Stock Exchange will be performed by posting on the Company website, etc.

7. Quiet Period

In order to prevent leakage of information that may affect the stock price during the preparation of the financial results (quarterly / full-year) presentation materials and to ensure fairness, the Company will set the period from the day following the financial closing date to the financial results announcement date as a "Quiet Period." During this period, the Company will refrain from commenting on the financial results or answering inquiries, etc. However, during the period, if it is anticipated that the business forecast will be greatly revised, the Company will promptly disclose this fact based on the Tokyo Stock Exchange "Timely Disclosure Rules," etc. Note that even during the Quiet Period, the Company will respond to inquiries regarding information already published.

End of document