Disclosure Policy

Basic Policy

Excluding confidential information and information contractually obligated to be kept confidential, the Company discloses to stakeholders such information as is useful to them, including information on management, the financial condition, environmental protection, and community and social contributions, in a fair and timely manner. The Company also strives to build and maintain positive relationships with stakeholders through open and fair communication.

Information Disclosure Standards

The Company discloses important corporate information in a timely and appropriate manner in accordance with laws and regulations, including the Financial Instruments and Exchange Act and the timely disclosure rules enacted by financial instruments exchanges. As for any information deemed useful to shareholders and investors, as well as to other stakeholders, even where such laws and regulations and the timely disclosure rules do not apply, the Company strives to proactively disclose such information in an appropriate manner.

The Company has established the Disclosure Committee for review and deliberation concerning information disclosure from multiple perspectives of various departments.

Information Disclosure System

The Company has a system in place to ensure that corporate decisions and information on financial results are managed by the officer responsible for handling information and the Disclosure Committee in an integrated manner. Of the important matters reported, those that require institutional decisions are submitted by the officer responsible for handling information and the Disclosure Committee to the Board of Directors or the Management Meeting whose membership includes executive officers, which are the Company’s important decision-making bodies, for prompt decision-making.

If a material fact comes to light, the department that recognizes such fact promptly communicates the information to the Disclosure Committee and the information will be reported to the officer responsible for handling information. The officer responsible for handling information will take the lead in examining the information, and if it is determined that timely disclosure is necessary, the information will be promptly disclosed via the Company’s important decision-making bodies.

Information Disclosure Method

The Company discloses important corporate information to which the timely disclosure rules apply through the TDnet (Timely Disclosure Network) system provided by the Tokyo Stock Exchange, while posting the same information on its website as quickly as possible.

As for any information that is deemed to help stakeholders better understand the Company, even where the timely disclosure rules do not apply, the Company strives to disclose such information by posting it on its website and by any other appropriate means.

Insider Information Management System

The Company has established the Regulations on Prohibition of Insider Trading and Management of Insider Information.

Persons engaged in dialogues concerning IR activities are restricted to the Company’s senior executives (Directors and Executive Officers), including the officer responsible for promotion of IR activities (director in charge of IR), to ensure information control.

Handling of Earnings Forecasts and Forward-looking Statements

Forward-looking statements that include earnings forecasts disclosed by the Company are based on information the Company possesses at the time of disclosure and certain assumptions the Company judges reasonable, and the Company shall give no guarantee for the accuracy of the statements. Additionally, please note that actual business results may substantially differ from announced earnings forecasts due to changes in the economic or business environment in which the Company operates.

Quiet Period

The Company sets as a quiet period the period from the day immediately after the closing date until before the announcement of the relevant financial statements to prevent the leakage of information affecting share prices and thus ensure fairness among shareholders and investors. During the quiet period, the Company does not respond to questions or comment on the account settlement and earnings forecasts. However, the Company discloses the information in a timely manner according to the timely disclosure rules when the probability emerges during the quiet period that large differences may arise between earnings forecasts and actual business results.