Management Policy

Disclosure PolicyIR Information

In accordance with the laws and regulations such as the Financial Instruments and Exchange Act, and “Timely Disclosure, etc. of Company Information” of the Securities Listing Regulations as stipulated by the Tokyo Stock Exchange (hereinafter referred to as “timely disclosure rules”), we will promptly disclose information based on transparency, fairness and continuity. Also, even if it does not fall under any of the laws and regulations or timely disclosure rules, we actively and fairly disclose information that is deemed important or useful for shareholders and investors to understand our company.
We do not disclose personal information, customer information, and information that would infringe the rights of related parties.

Statutory disclosure

We will make timely and appropriate disclosures in accordance with the legal disclosure system based on the Companies Act, Financial Instruments and Exchange Act, etc., and the timely disclosure rules established by the Tokyo Stock Exchange. In addition, in accordance with the spirit of fair disclosure, we will also disclose financial information and non-financial information that do not fall under the timely disclosure rules, such as the content presented at semiannual results briefings, we have a policy of making disclosure as proactive and fair as possible, in order to meet the needs of investors.

Definition of disclosure information
Disclosure based on the Financial Instruments and Exchange Act Financial statements, quarterly reports, extraordinary reports, etc.
Disclosure under the Companies Act (Business) Report, Financial Statements and Consolidated Financial Statements, etc.

Disclosure required by the Tokyo Stock Exchange
Timely disclosure Decision facts and occurrences that require timely disclosure from the Tokyo Stock Exchange, etc.
Other Corporate Governance Report

Other information disclosure
IR related disclosure materials (Financial results explanatory materials, etc.)

Method of information disclosure

Disclosure of information prescribed by the Timely Disclosure Rules will be conducted through the Timely Disclosure Information Transmission System (TDnet) provided by the Tokyo Stock Exchange in accordance with the rules. In addition, once released by the system, it will be promptly posted on our website.With regard to information that does not fall under the Timely Disclosure Rules, information that we have determined to be important or useful will be widely disclosed by posting on our website.

Prevention of insider trading

With regard to the prevention of insider trading, we have established information management rules and insider trading management rules to prevent them. In addition, each year, we hold study sessions on insider trading regulations for executives and employees, distribute commentaries, and strive to ensure that employees understand and understand their purpose.

Silent Period

From the viewpoint of preventing leakage of financial information (including quarterly financial information) and ensuring fairness of information disclosure, we set a silent period from the day after the final day of the financial statements (quarterly financial results) to the date of each financial results announcement. During this period, we will refrain from answering or commenting on questions regarding financial results and performance forecasts. However, if there is a possibility that the performance forecast will significantly change during this period, we will make appropriate announcements in accordance with the Timely Disclosure Rules.

About the maintenance of internal system

In accordance with the Disclosure Policy, we are working to maintain and improve our internal system in order to appropriately disclose information in accordance with the laws and regulations and the timely disclosure rules.

Timely disclosure system

Information acquired by the Company will be consolidated under the person in charge of timely disclosure (director of director's management department). And, after necessary examinations and procedures, the information to be released will be released in a timely manner.
Timely Disclosure System

Spokespersons for investor relations activities

To ensure the fairness of disclosure, we will designate the president & CEO, director & CFO, and president's office in charge of IR as spokespersons in communication with investors. In order to ensure consistency of disclosure content and avoidance of selective disclosure, other officers and employees should not communicate with investors in principle. If they do this, they will do so to the extent permitted by the spokesperson. In disclosing information, spokespersons make judgments on materiality through discussions with the job regulations or the president & CEO, and the director & CFO.
Each director and employee must provide the spokesperson with the details of any significant progress in our business through a defined chain of command. In addition, senior executives, including executive officers, will provide necessary and timely instructions to staff members in order to contribute to an effective disclosure process.
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