Disclosure Policy
1. Basic Policy
The Company positions the provision of corporate information—such as management policies, business strategies, business performance, and financial condition—to shareholders, investors, and other stakeholders in a fair, timely, and accurate manner as one of its important management priorities.
2. Standards for Information Disclosure
The Company conducts information disclosure in accordance with relevant laws and regulations, including the Financial Instruments and Exchange Act, and the rules established by the Tokyo Stock Exchange, namely the “Rules Concerning Timely Disclosure of Corporate Information by Issuers of Listed Securities” (hereinafter referred to as the “Timely Disclosure Rules”).
3. Methods of Information Disclosure
Disclosure of information that falls under the Timely Disclosure Rules will be made through the Timely Disclosure Network (TDnet) provided by the Tokyo Stock Exchange.
4. Information Disclosure System
The Company has established the Corporate Planning Department as the department responsible for timely disclosure and has built a system to appropriately disclose information aggregated from each internal department and group company under the supervision of the person responsible for information handling (Executive Officer in charge of the corporate domain). With respect to the appropriateness of disclosed information, the Company will, as necessary, collaborate and consult with the legal department, accounting auditors, and others. For decisions and financial information, disclosure will be made promptly after reporting to and confirmation by the Executive Committee; for occurrence-based facts, disclosure will be made promptly after approval by the person responsible for timely disclosure and others.
5. Handling of Forward-Looking Information
Among the information disclosed by the Company, statements other than historical facts are forward-looking statements based on the Company’s judgments using information currently available and include various uncertainties such as changes in economic conditions and market environments.
6. Quiet Period
In order to prevent the leakage of financial information and ensure fairness, the Company designates the period from three weeks prior to each quarterly earnings announcement date until the earnings announcement date as a “quiet period.” During this period, the Company will refrain from responding to inquiries or making comments regarding financial results and earnings forecasts. However, even during the quiet period, if a significant discrepancy between earnings forecasts and actual results is expected, the Company will disclose information as appropriate in accordance with the Timely Disclosure Rules.
7. Disclosure to Third Parties and the Fair Disclosure Rule
The Company complies with the Fair Disclosure Rule (Article 27-36 of the Financial Instruments and Exchange Act) and thoroughly manages information to prevent the selective disclosure of material information (as defined in Article 27-36 of the Financial Instruments and Exchange Act; the same shall apply hereinafter) only to certain transaction counterparties. In the event that material information is unintentionally conveyed to certain transaction counterparties, the Company will promptly publicly disclose such information in accordance with the Fair Disclosure Rule (Article 27-36 of the Financial Instruments and Exchange Act).
8. Prevention of Insider Trading
The Company separately establishes “Regulations for the Prevention of Insider Trading” and strictly operates rules regarding the management of material information and the trading of shares by officers and employees. In addition, in dialogues with shareholders and investors, the Company will not refer to undisclosed material information.