Disclosure Policy

1.Disclosure standards

The Company shall promptly disclose information based on the principles of transparency, fairness and continuity, in accordance with the Financial Instruments and Exchange Act and other applicable legislation, and with requirements for the timely disclosure of corporate information set out in the Tokyo Stock Exchange (TSE) Securities Listing Regulations (hereinafter “Timely Disclosure Regulations”). Even if information is not covered under legislation or Timely Disclosure Regulations, the Company shall actively and fairly disclose information that it deems to be important or beneficial to shareholders and investors, to provide a better understanding of the Company.
The Company shall not disclose personal information, customer information or any other information that infringes on the rights of those concerned.

2.Methods of disclosure

Information specified under Timely Disclosure Regulations shall be disclosed via the timely disclosure system provided by TSE (TDnet), in accordance with the relevant regulations. After it has been made public via the relevant system, information shall then be posted on the Company's website without delay. Even if information is not covered under Timely Disclosure Regulations, the Company shall extensively disclose information that it deems to be important or beneficial, including posting on the Company's website.

3.Preventing insider trading

The Company shall set out Ethics and Compliance Regulations, and Insider Trading Prevention Regulations, in order to prevent insider trading. The Company shall also make every effort to raise awareness and improve understanding, through measures such as organizing annual seminars on Insider Trading Regulations for officers and employees, and distributing explanatory materials, and shall call attention to insider trading as necessary via its internal reporting system.

4.Handling forecasts and forward-looking statements

All forecasts, projections, strategies, targets and other such information disclosed by the Company are classed as “forward looking statements” unless they relate specifically to the past or established facts in the present. Such statements are based on projections, expectations and judgments made by the Company based on information available at the current time and specific criteria deemed to be reasonable. As such, there is a possibility that actual results may vary from forecasts and other such information disclosed by the Company, due to uncertain variables such as economic conditions.

5.Quiet periods

The Company shall set aside a quiet period from the day after last date of the reporting period (end of each quarter) until the date on which its results are published, in order to prevent results (including quarterly results) from being leaked and to ensure fair disclosure. During this period, the Company shall not respond to questions or make comments regarding its results or forecasts. If results are expected to deviate significantly from forecasts however, the Company may disclose information as and when necessary in accordance with Timely Disclosure Regulations.

6.Establishing internal systems

In accordance with this Disclosure Policy, the Company shall establish and continue to improve internal systems for the purpose of adequately disclosing information in accordance with legislation and Timely Disclosure Regulations.

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