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. In addition to complying with laws and regulations and stock exchange rules, we will strive to build relationships of trust and enhance corporate value by reflecting opinions obtained through dialogue into our corporate activities and increasing management transparency.

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”). Furthermore, even for information that does not fall under the Timely Disclosure Rules, the Company has a policy of proactively and fairly disclosing information that is considered to have a material impact on the investment decisions of shareholders and investors, as well as information that is useful for deepening understanding of the Company’s business activities.

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. In addition, securities reports and other disclosures based on the Financial Instruments and Exchange Act will be made through EDINET. Information disclosed via TDnet will, in principle, be promptly posted on the Company’s website. Furthermore, for information that does not fall under the Timely Disclosure Rules, the Company will disclose such information broadly through appropriate methods, including posting materials on its website, in accordance with the importance and urgency of the information.

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. Within the Company’s group (meaning the Company and its subsidiaries over which the Company has management control), the Company ensures that the purpose and content of this policy are fully communicated to each group company and has established a system to appropriately guide and supervise each company’s efforts related to information disclosure.

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. Accordingly, please note that actual performance and other results may differ from the disclosed forecasts due to these factors.

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.