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1. Basic policy regarding information disclosure

In order to achieve sustainable growth and increase corporate value over the medium to long term, we aim to realize honest and highly transparent management that earns the trust of our stakeholders, and strengthen our corporate governance and enhance internal controls.  Appropriately disclose financial information such as the company's financial condition and operating results, as well as non-financial information such as information related to business strategies, management issues, risks in business activities, and corporate governance, based on laws and regulations. In addition to providing information in an appropriate manner as necessary, we also provide explanations and dialogue with shareholders directly or indirectly.

Information that has a significant impact on investment decisions will be disclosed in accordance with timely disclosure rules, and as necessary, posted on our website or disclosed to the press, so that all market participants can access it equally. We have put in place a system to make this possible.

By disclosing information in a timely, appropriate, and fair manner to our shareholders and other stakeholders, we strive to further enhance our credibility as a company and obtain an appropriate evaluation of our corporate value in the capital market.

If it is discovered that there was an error in information disclosed in the past, the error will be promptly corrected and disclosed. We will also promptly update information if there is a major change in the situation.

2. Initiatives towards dialogue

In order to achieve sustainable growth and increase corporate value over the medium to long term, our company recognizes that one of the important management issues is to appropriately reflect shareholder opinions in management. The executive officer responsible for business promotion will be in charge of conducting dialogue with shareholders and investors to gain understanding of the Company's management strategy and business plan. In addition, by reporting the opinions obtained through dialogue to Board of Directors and other parties as necessary, we strive to gain a balanced understanding of the positions of various stakeholders and respond appropriately based on that understanding.

3. Internal system related to timely disclosure of material facts

Our company has an "Information Disclosure Committee," which is comprised of the information handling officer and the persons in charge of departments related to legal and timely disclosure (finance, legal affairs/general affairs, and management promotion). We will make a negative judgment and Board of Directors / Executive Committee will instruct disclosure. In addition to regular audits, they receive advice and guidance from corporate Audit and Supervisory Board Member and Accounting audit. Furthermore, when making deliberations and decisions, advice and guidance will be obtained from outside experts, including lawyers, as necessary.

Information disclosure system

(as of July 2023)

4. Definition of material information and disclosure method

(1) Timely disclosure information

Important information regarding a company's business, operations, or performance that has a significant impact on investment decisions for securities that is required to be disclosed according to the timely disclosure rules established by financial instruments exchanges (information regarding decisions regarding listed companies and subsidiaries, occurrence facts) information regarding financial statements and financial results, etc.), we will conduct disclosure procedures in accordance with the timely disclosure rules established by financial instruments exchanges, and will post it on our website and make public announcements to the press as necessary.

(2) Important information subject to fair disclosure rules

Although we strive to appropriately manage important information that has not been made public regarding the company's management, business, or assets and that has a significant impact on investors' investment decisions, in the unlikely event that some information If the information is communicated to parties involved in the transaction, the information will be disclosed 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). We will post information on our website and make public announcements to the press as necessary.

(3) Legally disclosed information

Important information that is required to be disclosed by law under the Financial Instruments and Exchange Act will be disclosed appropriately in accordance with the law. We will post information on our website and make public announcements to the press as necessary.

5. Preventing insider trading

In order to properly manage important information and prevent insider trading, we have established internal regulations and are promoting awareness and awareness activities throughout Group.

6. Improving fairness in information access

In order to provide investors with fair access to timely disclosure, the Company will make disclosures on its website in addition to filings and press releases at each stock exchange, and will do so at the same time.

If a spokesperson designated by our company discloses material non-public information contrary to the original intention at various briefing sessions with investors, we will promptly make the disclosure in a timely manner. Similarly, if material non-public information that originally requires timely disclosure is disclosed by a third party prior to disclosure by the Company, we will promptly disclose it in a timely manner.

7. Quiet period

In order to prevent the leakage of financial results information, our company will maintain a quiet period from the day after the final financial year and each quarter's financial results until the day the financial results are announced, and during this period we will refrain from making any new comments related to financial results information. However, if during the relevant period it appears that the results are expected to deviate significantly from previous forecasts, disclosure will be made in accordance with timely disclosure rules. Please note that even during the quiet period, we will respond to inquiries regarding information that has already been made public.

8. Regarding future outlook

The plans, future outlook, strategies, etc. of Group published in the Company's disclosure materials, except those that are contrary to past or present facts, are forecasts regarding future performance, and these are currently available to the Company. This is based on the judgment and assumptions of our management based on available information. Therefore, actual results may differ significantly due to uncertainties, economic conditions and other risk factors.

As a general rule, we do not comment if a third party expresses an opinion regarding the future of our company. However, if there are obvious factual errors or mistakes in the third party's comments, we may point them out on our website.

9. Responding to market rumors

Our company does not comment on market rumors, whether confirming or denying them.

When rumors and reports circulating about our company are deemed to have a major impact on the capital market and it is necessary to clarify the truth, we will appropriately disclose information through the Timely Disclosure Information Transmission System (TDNet), etc. To do.