Disclosure Policy

(1) Information disclosure criteria

In accordance with the provisions of the Financial Instruments and Exchange Act and other pertinent laws and regulations and the “Rules on the Timely Disclosure of Corporate Information” (hereinafter referred to as “Timely Disclosure Rules”) of Tokyo Stock Exchange’s securities listing regulations, we will promptly disclose information based on transparency, fairness and continuity. In addition, even where not required under pertinent laws and regulations or the Timely Disclosure Rules, we will proactively and fairly disclose information that we deem important for our shareholders’ understanding of the Company, or otherwise beneficial to them.

In addition, we will not disclose personal information, customer information, or information that may infringe the rights of interested parties.

(2) Method of disclosure of information

Information stipulated by the Timely Disclosure Rules is disclosed through the Timely Disclosure Information Transmission System (TDnet) provided by the Tokyo Stock Exchange in accordance with said Rules, and after being disclosed through this system, is promptly posted on the Company’s website. Even if the information does not fall under the Timely Disclosure Rules, we will widely disclose information that we judge to be important or useful, such as by posting it on our website.

(3) Prevention of insider trading

The Company has established internal regulations aimed at the prevention of insider trading. In addition, study sessions on insider trading regulations are held every year for Company officers and employees, and instruction materials distributed in order to ensure a thorough awareness and understanding of the content and meaning of the regulations, and internal notices issued as appropriate in order to enhance awareness of insider trading.

(4) Handling of business forecasts and forward-looking information

Earnings forecasts, future prospects, strategies, targets, etc. disclosed by the Company, other than those relating to past or current facts, are forward-looking statements, which are based on the information available to the Company at the time, and are grounded on plans, expectations, and judgments based on certain assumptions that are judged to be reasonable. Therefore, actual results may differ from the disclosed performance forecasts, etc. due to fluctuations in a variety of uncertain factors such as economic conditions.。

(5) Silent period

The Company has designated the period from the day following the closing of the financial results (quarterly accounts) till the day of the announcement of the financial results a period of silence, from the perpsective of preventing the leaking of financial information (including quarterly financial information) and of ensuring the fairness of information disclosure. During this period, the Company will refrain from answering or commenting on questions about financial results and earnings forecasts. However, if there is an expectation that the earnings forecast will fluctuate significantly during this period, we will make an appropriate announcement in accordance with the Timely Disclosure Rules.