Disclosure Policy

1.bjective and Basic Policy of IR Activities

The Company recognizes the General Meeting of Shareholders as a forum for constructive dialogue with shareholders. Considering the shareholders’ perspective, the Company provides accurate information through convocation notices and so forth, allowing sufficient time for consideration. The Company also takes steps to provide information in an easily understandable format at the General Meeting of Shareholders, including visual presentation. Through these efforts, the Company strives to create an environment where shareholders can exercise their rights appropriately.

Moreover, the Company’s representative director and executive officers etc. responsible for the administrative division actively strive to engage in dialogue with shareholders, emphasizing fairness, accuracy and continuity in management strategies, business strategies, financial information and other aspects and promoting investor relations (IR) activities designed to achieve strong two-way communication under the following policy.

  1. The executive officers responsible for the administrative division are designated as the management team in charge of overall direction of the dialogue with all shareholders.
  2. In its administrative division, the Company assigns people responsible for gathering, managing and disclosing information and people in charge of executing these functions. These assigned people cooperate with relevant departments to conduct timely, fair and accurate disclosure of information.
  3. The Company strives to promote investment opportunities and enhanced disclosure of information by holding results presentations at the time of announcement of the first half financial results and the full-year financial results, as well as presentations for private investors and by publishing a Letter to Shareholders.
  4. To reflect shareholders’ opinions in management, when objectively important feedback is received, it is reported to the Board of Directors, thereby sharing desires, opinions and awareness of issues from shareholders.
  5. The Company takes steps to prevent leakage of financial results information and ensure the timeliness, synchronicity and fairness of its information disclosures. To this end, as explained in 2. (5) below, the Company has established a quiet period during which time it does not respond to questions or make comments regarding its financial results. Furthermore, the Company has established Insider Information Management Regulations and implements controls over information in an effort to manage insider information.

2.olicy and Standards for Information Disclosure

(1)Disclosure Standards

The Company conducts timely disclosure of information in accordance with the Companies Act, the Financial Instruments and Exchange Act and other relevant laws and regulations, as well as the securities rules relating to timely disclosure set out by the Tokyo Stock Exchange (“timely disclosure rules”). Under the timely disclosure rules, timely disclosure is required in the following cases: where important company information is decided or occurs, where there has been a referral from the Tokyo Stock Exchange and where material changes or cancellations have been made to important company information that has already been disclosed.

The Company will also strive to actively and fairly disclose information that is not covered by the timely disclosure rules, such as announcements made at Company presentations, as far as possible to meet investors’ demands.

(2)Methods of Information Disclosure

Disclosure of information covered by the timely disclosure rules will be disclosed in accordance with the rules through the timely disclosure system (TDnet) provided by the Tokyo Stock Exchange. Information disclosed through TDnet will be promptly posted on the Company’s website.
Furthermore, due to the preparation status of tools and systems, such information may be posted on the Company’s website significantly later than its disclosure through TDnet.

Furthermore, when disclosing information that is not covered by the Companies Act, the Financial Instruments and Exchange Act and other laws and regulations, as well as the timely disclosure rules, the Company’s basic policy is to give consideration to communicating the information to ordinary investors as accurately and fairly as possible through appropriate methods based on purport of timely disclosure.

(3)Forward-Looking Statements

In addition to financial results information disclosed in accordance with the timely disclosure rules, the Company may also provide guidance regarding forecasts to enable investors and securities analysts to develop their own predictions with regard to the Company’s performance.
The Company’s current plans, forecasts and strategies etc. may also be included in its greetings, lectures, responses to questions, documents issued by the Company, website content and so forth.
In any of these cases, statements that are not historical facts are forward-looking statements that are made under certain assumptions and reflect the judgement of the Company’s management based on currently available information.

Therefore, when examining the Company’s performance, corporate value and other aspects, you should not rely entirely on these forecasts alone. You should be aware that actual results may differ significantly from the forecasts due to various factors.

Material factors that can impact actual results include, but are not limited to, (1) risks relating to the Company’s business environment and specific legal regulations, (2) risks that have an impact on management results and financial condition and (3) risks related to the Group’s business operation structure. For further details of operational risks and so forth, please refer to “4. Business Risks” in the Annual Securities Report (Japanese Only) posted separately on the website.

(4)Positioning of the Company’s Website

The Company’s website has been established for the use of people who wish to search for Company information on the Internet. To ensure fair information disclosure, it is posted on the Company’s website as quickly as possible after disclosure; however, since there may be a delay in the time of posting on the website due to faults and so forth with ICT systems, information disclosure on the Company’s website should be considered only as an expedient and auxiliary measure.

Furthermore, the Company’s website may not include all of the information disclosed by the Company. Moreover, the language of the information may differ from that used in disclosures made by other methods. You should understand these points clearly when making use of the Company’s website.

(5)Quiet Period

To prevent the leakage of information that could impact the Company’s share price during the preparation period for financial results announcement materials, the Company has established a “quiet period” from the day following the closing day of the financial period until the day of results announcement. During this period the Company refrains from making comments or responding questions regarding its financial results. However, if a forecast that differs materially from expected forecast arises during the quiet period, the Company will disclose the information appropriately through a press release.