Disclosure Policy

1. Basic Policy

The Company recognises that it is an extremely important responsibility to appropriately communicate information affecting investment decisions to shareholders, investors, and other stakeholders. The Company will disclose information in a timely and appropriate manner, based on the principles of transparency, promptness, and continuity.
The Company will strictly comply with the obligation to disclose information based on laws and regulations regarding financial information, such as financial position and operating results, as well as management strategies and management issues, risks in business activities, and non-financial information related to corporate governance. In addition to disclosure in accordance with laws and regulations, the Company will actively disclose information in an appropriate manner on matters deemed necessary.

2. Approach to Dialogue

The Company recognises that it is its duty to appropriately reflect the opinions of shareholders and investors in its management in order to increase corporate value over the medium to long term. The Company will therefore endeavour to maintain close communication with shareholders and investors through continuous dialogue.

3. Information-disclosure Structure

The Company centralises decisions made by representatives (Representative Director and President), Information Handling Supervisors (Executive Managing Officer and General Manager of Corporate Management HQ), IR Division of Corporate Management HQ which is in charge of timely information disclosure, and material facts that have arisen in the respective divisions without delay. IR Division determines the necessity of timely disclosure, and when timely disclosure is required, in cooperation with related divisions, prepares specific details of disclosure. Subsequently, IR Department shall act as the contact point and disclose such information on a timely basis under the direction of the Information Handling Supervisor after making decisions at meetings of the Board of Directors.

4. Definition and Disclosure of Important Information

(1) Timely disclosure information

Material information on the business, operation, or performance of the Company that significantly affects the investment decisions of securities required to be disclosed pursuant to the Timely Disclosure Rules established by the Tokyo Stock Exchange (such as information on the decisions of listed companies and subsidiaries, information on the events that have occurred, and information on the settlement of accounts) shall be disclosed in the Timely Disclosure Information Communication System (TDnet) in accordance with the Timely Disclosure Rules established by the Tokyo Stock Exchange. After registering as the TDnet, the Company will post it on its website and publish it to the press.

(2) Important information subject to the Fair Disclosure Rule

The Company strives to appropriately manage important information that is not publicly disclosed regarding the Company's operations, operations, or assets and that has a material impact on investors' investment decisions. However, in the event that such information is communicated to a certain party involved in a transaction, the Company will disclose it in accordance with the Fair Disclosure Rules (Article 27-36 of the Financial Instruments and Exchange Act and the Cabinet Office Ordinance on Publication of Important Information). If necessary, the report will be posted on the Company's website and published to the press.

(3) Statutory disclosure information

The Company will appropriately disclose important information that is required to be disclosed by law under the Financial Instruments and Exchange Law in accordance with laws and regulations. If necessary, the report will be posted on the Company's website and published to the press.

5. Managing Inside Information

To appropriately manage important information and prevent insider trading, the Company has established regulations and are promoting awareness-raising activities throughout the Company.

6. Quiet Period

In order to prevent the leakage of financial information and ensure fairness, the Company makes the period from the day following the closing date to the announcement of the financial statements silent. During this period, the Company refrains from responding to questions or comments related to the financial information. However, in the event that a matter that meets the timely disclosure standards occurs, such as when there is a prospect that results are significantly outside the previous forecasts during the period, the Company will disclose the matter in accordance with the Timely Disclosure Rules. Even during the quiet period, the Company will respond to inquiries about the scope of information that has already been disclosed.

7. Forward-looking Statements

Statements contained in the Company's disclosure with respect to its plans, forecasts and strategies, other than statements of historical or current facts, are forward-looking statements based on its management's beliefs and assumptions in light of information currently available to the Company. Accordingly, actual results may differ significantly from these forecasts due to uncertainties, economic conditions and other risk factors.
In principle, the Company will not comment if a third party comments on the Company's future. However, if the Company determines that there is an obvious mistake or error in the comments of the third party, the Company may point out such mistake on its website.

8. Responding to Unclear Information

The Company does not comment on unclear information about the Company, including affirmation and denial.
Provided, however, that the Company will disclose such information appropriately through the TDnet and other means when it is deemed that the rumours and news circulated to the Company have a significant impact on the capital markets. Therefore, if the Company determines that there is a need to clarify the truth and falsity of the information, it will disclose such information appropriately.

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