Disclosure Policy for Investors

Statement of Commitment

  1. We shall disclose information to our investors in a timely, proper, and fair manner.
  2. We shall actively engage in dialogue with them, and reflect their comments in our business activities properly.
  3. Through disclosure and dialogue, we shall be committed to further enhance its transparency and fairness, and shall strive to build and maintain a trust relationship with our investors.

Standards for disclosure

  1. We shall conduct disclosure based on the Timely Disclosure Rules stipulated by the Tokyo Stock Exchange (hereinafter, referred to as "Timely Disclosure Rules") and the relevant laws and regulations including Financial Instruments and Exchange Act.
  2. We shall positively and fairly disclose information which does not come under the relevant laws and regulations, and Timely Disclosure Rules but we consider useful for investors’ investment decision.
  3. We shall observe so called “Fair Disclosure Rules” set in the Financial Instruments and Exchange Act concerning fair and appropriate information disclosure, control as-yet-undisclosed material information which may significantly affect the Company’s stock price, and shall fairly deliver relevant material information to investors.

Methods of Disclosure

  1. “Timely Disclosure Information” shall be made public through the Timely Disclosure Network (TDnet) provided by the Tokyo Stock Exchange and, promptly after such public disclosure, made available via the Company's IR website.
  2. Information other than above shall be also disclosed in a manner appropriate for the content.

Internal System Related to Disclosure

  1. The officer of General Affairs shall be responsible for the Timely Disclosure, and the Public Affairs department shall manage it.
  2. In case of disclosure, Public Affairs department shall cooperate with the relevant department such as IR department and shall determines the content of disclosed information.
  3. A monitoring process shall be in place to evaluate the operation and maintenance of internal systems related to the disclosure.

Quiet Period

  1. In order to prevent leaks of financial results and forecast information before disclose and ensure fairness, we shall implement a "quiet period" from end of each quarter to the announcement of results, and shall refrain from making comments and responding to questions about the results during the current period.
  2. We don’t conduct disclosure in a “quiet period”, unless material events subject to Timely Disclosure have occurred.

Revised on January 1,2022