1. Criteria for Disclosure

In accordance with the Financial Instruments and Exchange Act and other laws and regulations of Japan, as well as “Timely Disclosure of Company Information, etc.” in the listing regulations for marketable securities of the Tokyo Stock Exchange (hereinafter “the Timely Disclosure Regulations”), the Company practices prompt disclosure, based on the principles of transparency, fairness and continuity. Even in the case of information to which the law and the Timely Disclosure Regulations do not apply, the Company actively and fairly discloses said information if it judges that said information is important or beneficial in terms of enabling shareholders and investors to understand the Company.
The Company does not disclose personal information, customer information or any information whose disclosure may violate the rights of the related parties.

2. Methods of Disclosure

The Company discloses the information specified in the Timely Disclosure Regulations through TDnet, a system provided by the Tokyo Stock Exchange for the transmission of information for timely disclosure. After disclosure on TDnet, the Company promptly posts the same information on its website.
Even in the case of information to which the Timely Disclosure Regulations do not apply, if it judges said information to be important or beneficial, the Company discloses said information through its website, to ensure wide circulation.

3. Prevention of Insider Trading

The Company has established a series of regulations for the prevention of insider trading. These include the Insider Trading Prevention Regulations, the Internal Information Management Regulations, the Confidentiality Management Regulations and the Compliance Regulations. In addition, the Company provides its directors and employees with training and other opportunities to learn how to prevent insider training, thereby instilling vigilance against insider trading.

4. Quiet Periods

To prevent leakage of financial information (including quarterly financial information) and ensure fair disclosure, the Company establishes a quiet period after each settlement date (including quarterly settlement dates), lasting from the day after the settlement date to the date of announcement of the financial results. During this period, the Company refrains from answering questions or commenting on the settlement of accounts or forecasts of business results.
If, however, an event occurs during this period that is expected to alter significantly the forecast of business results, the Company makes an appropriate announcement in accordance with the Timely Disclosure Regulations.

5. Formation of Company-Internal Systems

The Company is working hard to prepare and enhance its internal systems for timely disclosure, in accordance with this Disclosure Policy, applicable laws and regulations of Japan and the Timely Disclosure Regulations.

6. Forecasts of Business Results and Other Future-Oriented Statements

Future-oriented statements by the Company, including disclosure of forecasts of business results, strategies and targets, are based on information available to the Company at the time of their preparation and on assumptions the Company judges to be reasonable. Actual results may differ significantly, due to a wide range of factors.

Established: April 11, 2019