DISCLOUSURE POLICY

Disclosure

Information Disclosure Standards

We strive to provide information promptly to shareholders and investors based on transparency and fairness. In addition to disclosing information in accordance with the Financial Instruments and Exchange Act and other laws and regulations and the timely disclosure rules set forth by the Tokyo Stock Exchange, we also strive to disclose information in a timely and proactive manner that we believe will be useful in helping shareholders and investors understand our company.

Method of Disclosure

Information subject to the timely disclosure rules is disclosed through the timely disclosure electronic information system (TDnet) provided by the Tokyo Stock Exchange, and securities reports and quarterly reports based on the Financial Instruments and Exchange Act are disclosed through the electronic disclosure system (EDINET) of the Financial Services Agency. In principle, the disclosed information will also be promptly disclosed on our IR website. In addition, for other information that does not fall under the timely disclosure rules but that is deemed useful to stakeholders, our policy is to disclose such information promptly and fairly in an appropriate manner, based on the purpose of the fair disclosure rules set forth in the timely disclosure Financial Instruments and Exchange Act.

Prevention of Insider Trading

We have established internal regulations for the appropriate management of important information and the prevention of insider trading, and promotes thorough awareness, understanding, and enlightenment of all officers and employees.

Quiet Period

To ensure fairness to investors, we observe a quiet period from the day following the end of each quarter until the day of each financial announcement.  During this period, we refrain from answering questions or making comments regarding financial results and business outlook. However, if there are any prospects that our business results will deviate significantly from our forecasts during the quiet period, we will disclose the information as appropriate in accordance with the timely disclosure rules.

Internal System Development

In accordance with this disclosure policy, we are working to improve and enhance our internal systems to ensure appropriate information disclosure in accordance with applicable laws and regulations and timely disclosure rules.

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