Disclosure Policy

Traded as : 7537 (TYO)

Basic Policy

 The Company will disclose information in a timely and appropriate way to stakeholders and carry out investor relations activities to improve two-way communications with shareholders and investors in order to gain their confidence.

Criteria for Disclosure

 The Company will disclose information in compliance with the Financial Instruments and Exchange Law, with other relevant laws and regulations and with the Timely Disclosure Rules set out by the Tokyo Stock Exchange.
 The Company will also disclose information that does not fall under the material facts as defined by the Timely Disclosure Rules in an active and impartial manner, provided that the information is considered useful to shareholders and investors.

Modes of Disclosure

 The Company will disclose information that falls under the material facts as defined by the Timely Disclosure Rules through the Timely Disclosure Network (TDnet) provided by the Tokyo Stock Exchange in accordance with the Timely Disclosure Rules.
 The Company will endeavor to publish disclosed information on the Company’s website as soon as possible. The Company will provide information other than mentioned above that is considered useful to shareholders and investors by distributing a press release, publishing it on the website and other means as appropriate.

Quiet Period

 To prevent the unauthorized disclosure of earnings information and to ensure fairness, the Company will observe a quiet period lasting two weeks immediately prior to the announcement of financial results. During the quiet period, the Company will refrain from commenting on or answering questions about earnings results. Even during the quiet period, however, the Company will disclose information in accordance with the Timely Disclosure Rules in the event of any possible material divergence from the earnings forecast announced.