Disclosure Policy

1. Basic Policy on Information Disclosure

  1. The Company provides that “We will disclose information as appropriate and ensure transparency of management” in our Corporate Code of Conduct and puts this into practice. In addition, our basic policy is to strive to ensure the rights and equal treatment of stakeholders, including shareholders and investors, through appropriate information disclosure.

2. Criteria and Methods of Information Disclosure

  1. The Company discloses information in accordance with relevant laws and regulations, including the Financial Instruments and Exchange Act, and the "Rules on Timely Disclosure of Corporate Information by Issuers of Listed Securities" (hereinafter referred to as the "Timely Disclosure Rules") set forth by the Tokyo Stock Exchange.
  2. In accordance with the Timely Disclosure Rules, the Company discloses information subject to timely disclosure via the Timely Disclosure Network (TDnet) operated by the Tokyo Stock Exchange, promptly provides the same information to the press, and posts it on the Company's website, etc.
  3. In addition, even for matters not subject to statutory or regulatory disclosure requirements, the Company discloses information deemed material on its website, etc., in a timely and appropriate manner as cases arise.

3. Internal Framework Pertaining to Timely Disclosure

  1. The Company has established a unified system to capture matters of internal information of the Company and the Company's subsidiaries that should be subject to timely disclosure at the Administrative General Affairs Division, Administration Headquarters.
  2. Specifically, the department in charge of the facts reports the details of the facts to the Administrative General Affairs Division, Administration Headquarters and the Administrative General Affairs Division, Administration Headquarters determines the specific method of disclosure with the approval of the President, after discussion with the relevant departments for such facts, the Public Relations Division and the Corporate Strategy Division, Corporate Strategy and Planning Headquarters (in charge of IR). The Public Relations Division shall disclose such facts based on this decision.
  3. The internal framework pertaining to the timely disclosure of the Company's corporate information is as follows.

Outline of Timely Disclosure System (schematic diagram)

4. Basic Policy on IR

  1. The Company regularly holds IR briefings and small meetings by the President, etc., inviting analysts and fund managers and others, with the aim of them understanding the Company’s management policy and management plans.
  2. How to respond to requests for an interview from a shareholder or investor is considered through collaboration among the division in charge of IR, the division in charge of SR, the division in charge of ESG and our Group companies according to the purpose of the interview, the importance of the content, and the attributes of the interviewee.
  3. Feedback and concerns from shareholders and investors gathered through IR briefings and interviews are reported to the President or the Board of Directors as and when needed.
  4. The President supervises overall dialogue with these shareholders and investors (IR activities), and to ensure their effectiveness, the Company has established a department and an officer in charge of IR within the Corporate Strategy and Planning Headquarters.

5. Quiet Period

  1. To manage insider information strictly and ensure fairness while preventing the leakage of financial results, the Company sets a quiet period from the day following the account closing date of each quarter until the announcement of that quarter's financial results, during which it refrains from creating opportunities for dialogue.

6. Cautionary Note Regarding Forward-Looking Statements

  1. Among the information disclosed herein, forward-looking statements such as earnings forecasts are based on information currently available to the Company and on certain assumptions deemed to be reasonable, and do not constitute assurances regarding their achievement by the Company. Furthermore, actual results may differ significantly from these forecasts due to various factors.

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