MANAGEMENT POLICY

1. Disclosure criteria

We promptly disclose information in line with the Financial Instruments and Exchange Act and other relevant laws and regulations, as well as the Timely Disclosure of Company Information rules (hereinafter the Timely Disclosure Rules) prescribed by the Tokyo Stock Exchange. We do this in a transparent, fair, and consistent manner. Even in cases that do not correspond to legal requirements or the Timely Disclosure Rules, we will proactively and impartially disclose information that we judge to be important or beneficial for shareholders and investors to understand our company. We do not disclose personal information, customer information, and other information that might infringe on the rights of related parties.

2. Methods of information disclosure

Information required to be disclosed by the Timely Disclosure Rules will be made available through the Timely Disclosure Network (TDnet) provided by the Tokyo Stock Exchange in accordance with said rules. Information made public through this system will also be promptly posted on our website. Even in cases where information does not fall under the Timely Disclosure Rules, information that we judge to be important or beneficial will be made available on our website.

3. Preventing insider trading

We have established rules for managing information and insider trading rules to prevent such activity. An annual study session on our insider training rules is held for executives and employees. We strive to raise awareness and deepen understanding of the reasons for these rules through efforts like distributing relevant educational materials. We also release internal notices as appropriate to warn about the issue.

4. Handling of earnings forecasts and forward-looking information

Other than information relating to past or current facts, earnings forecasts, future outlooks, strategies, targets, etc. disclosed by the Company all contain forward-looking statements. These are based on plans, expectations and judgments and rely on information available to the Company at the time of formulation and certain assumptions we have deemed reasonable. Therefore, actual results may differ from disclosed earnings forecasts and other forecasts due to various uncertain factors such as economic conditions.

5. Silent period

We observe a silent period from the day after the end of each fiscal quarter until the date of the corresponding earnings announcement, in order to prevent leakage and ensure fairness in information disclosure. During this period, we refrain from answering questions regarding or commenting on financial results and earnings forecasts. However, if during this period, we expect a significant change in the earnings forecast, we will make the relevant information public as appropriate in accordance with the Timely Disclosure Rules.

6. Internal systems

We ensure our internal systems always allow us to disclose information in accordance with our Disclosure Policy, various laws and regulations, and the Timely Disclosure Rules.