Disclosure Policy

1Disclosure Criteria

It is policy for the Company to carry out disclosures in accordance with the laws and regulations of the Financial Instruments and Exchange Act and the "timely disclosure of company information etc." (hereinafter referred to as the "timely disclosure rules") of securities listing rules established by the Tokyo Stock Exchange. In addition, even if it does not fall under any of the laws and regulations or timely disclosure rules, we will conduct fair and honest disclosure regarding information judged to be important or useful for shareholders and investors to understand our company.

2Method of Information Disclosure

Disclosure of important information that falls under the timely disclosure rules established by the Tokyo Stock Exchange will be disclosed in the “TDnet system” provided by the same exchange in accordance with said rules. Information released on the TDnet system will be promptly posted on our website. Also, when disclosing information that does not fall under the timely disclosure rules, we will take care to ensure that the information is transmitted as fairly as possible through our website and media.

3Prevention of Insider Trading

Regarding prevention of insider trading and actions like it, we have established the prevention of insider trading regulations, timely disclosure regulations, information management regulations, risk management, and compliance regulations, and more. We also hold study sessions on insider trading regulations for executives and employees every year, distribute commentary books and other relevant material, strive to thoroughly disseminate information to create deep understanding the issues, and appropriately conduct information to draw attention to issues regarding insider trading within the company.

4Handling of Business Forecast and Projections

Performance forecasts other than those related to past or present facts among the business forecasts, projections, strategies, targets, etc. disclosed by the Company are performance forecasts which are plans, expectations, and judgements based on certain assumptions that are determined to be reasonable. Therefore, actual business performance and results may differ from the disclosed business performance forecast due to fluctuations of various factors such as economic conditions.

5Established Period of Silence

In order to prevent leakage of financial information and ensure fairness, the period from the day after the end of quarterly financial results to the announcement of such financial results shall be a silent period. During this period, we will refrain from answering any inquiries related to the settlement of accounts. However, during the established silent period, information that falls under various laws, regulations, or timely disclosure rules will be disclosed timely and appropriately.