Disclosure policy

(1)Information Disclosure Standards

The Company will promptly disclose information based on transparency, fairness, and continuity in accordance with the Financial Instruments and Exchange Act and other relevant laws and regulations, as well as the “Timely Disclosure of Corporate Information, etc.” in Securities Listing Regulations established by the Tokyo Stock Exchange (hereinafter referred to as “Timely Disclosure Rules”). Even if the information is not among types of information required to be disclosed pursuant to relevant laws and regulations and the Timely Disclosure Rules, we will proactively disclose information which we consider important or helpful for shareholders and investors to better understand us.We will not disclose personal information, customer information, or information that may infringe upon the rights of related parties.

(2)Method of Information Disclosure

The information stipulated in the Timely Disclosure Rules is disclosed through the Timely Disclosure network (TDnet) system provided by the Tokyo Stock Exchange in accordance with the Rules. After disclosure through the system, the information is promptly posted on the website of the Company. We will also widely disclose information that is not subject to the Timely Disclosure Rules but is considered important or useful through such means as posting on our website.

(3)Preventing Insider Trading

As for the prevention, etc. of insider trading, the Company has established internal rules to prevent such insider trading. We also provide ongoing education and training, and prepare and distribute manuals so that officers and employees are fully informed of the purpose and content, etc. of the insider trading rules.

(4)Handling Results Forecasts and Future Information

Excluding matters related to past and current facts, results forecasts, forward-looking estimates, strategies and targets disclosed by the Company are estimates regarding the future. These estimates are formulated from plans, expectations, and judgments made based on information that the Company can obtain at the present time, as well as certain assumptions that are deemed reasonable. Accordingly, actual results, etc. may vary from the disclosed results forecasts, etc., due to variable factors with uncertainties, including the economic situation.

(5)Quiet Period

From the viewpoint of preventing the leakage of financial results information (including quarterly financial results information) and ensuring the fairness in information disclosure, the Company has designated a quiet period from the day following the last day of the fiscal year (quarterly settlement) to each financial statement announcement day. During this period, we will refrain from responding to or commenting on any questions regarding financial results or results forecasts. However, if the results forecasts are expected to change significantly during this period, we will announce such changes as appropriate in accordance with the Timely Disclosure Rules.

(6)Constructing Internal Structure

In line with this Disclosure Policy, the Company is striving to construct and enhance an internal structure in order to ensure appropriate information disclosure in accordance with relevant laws and regulations as well as the Timely Disclosure Rules.