(1) Standards for information disclosure

The Company provides prompt information disclosure based on the principles of transparency, fairness and continuity in accordance with applicable laws and regulations such as the Financial Instruments and Exchange Act and the “timely disclosure of corporate information” in the Securities Listing Regulations stipulated by the Tokyo Stock Exchange (hereinafter, “Timely Disclosure Rules”). We actively and fairly disclose information deemed relevant or beneficial to shareholders and investors to understand the Company even if it is not required by applicable laws, regulations or the Timely Disclosure Rules. We do not disclose personal information, customer information or information that could violate the rights of relevant parties.

(2) Method of information disclosure

The Company discloses the information prescribed in the Timely Disclosure Rules through the Tokyo Stock Exchange’s Timely Disclosure Network (TDnet) in accordance with such regulations, and promptly posts the same information on the Company’s website thereafter. Information deemed relevant or beneficial is widely disclosed such as through posting on the Company’s website even if it is outside the scope of the Timely Disclosure Rules.

(3) Prevention of insider trading

We aim to prevent insider trading and other misconduct by establishing rules for the prevention of insider trading. Apart from holding study groups on insider trading regulations for officers and employees every year, we distribute an instruction manual, and take other measures to strive for thorough awareness and understanding of the issue. At the same time, we issue internal notices as required to alert employees about insider trading.

(4) Handling of earnings forecasts and forward-looking statements

Information on earnings forecasts, future outlook, strategies and targets disclosed by the Company that are not related to past or current facts are forward-looking statements. These are based on information available at the time of preparation or on plans, expectations or decisions according to certain assumptions deemed reasonable. Therefore, actual earnings may differ from forecasts and other information disclosed due to changes in variable factors such as economic trends.

(5) Quiet period

To prevent leakage of information on financial results (including quarterly financial results) and to ensure fair information disclosure, the Company observes a quiet period that begins the day after the end of the fiscal period (and the end of each quarter) until the day on which the respective financial results are announced. We refrain from answering questions or commenting on the financial results and earnings forecasts during this period. However, any possibilities of a major deviation from earnings forecasts during this period will be announced as necessary in accordance with the Timely Disclosure Rules.

(6) Development of internal structure

The Company strives to develop and enhance the internal structure for the appropriate disclosure of information in accordance with laws, regulations and the Timely Disclosure Rules in line with this Disclosure Policy.