Disclosure Policy

(1) Information Disclosure Standards

In accordance with laws and regulations including the Financial Instruments and Exchange Act, as well as the “Timely Disclosure of Corporate Information, etc.” in the Securities Listing Regulations stipulated by the Tokyo Stock Exchange (hereafter the “Timely Disclosure Rules”), the Company shall promptly disclose information based on the principles of transparency, fairness and continuity. The Company will also proactively and fairly disclose information deemed to be important or valuable in helping shareholders and investors understand the Company, even when such information is not subject to laws and regulations or the Timely Disclosure Rules. However, personal information, client information, and information that may infringe upon the rights of a related party will not be disclosed.

(2) Information Disclosure Methods

The disclosure of information as stipulated in the Timely Disclosure Rules is conducted via the Timely Disclosure Network (TDnet) provided by the Tokyo Stock Exchange, in accordance with said rules. Following the disclosure via said system, the information is also promptly published on the Company’s website. Information deemed to be important or valuable is also widely disclosed via various methods including our website, even if it is not subject to the Timely Disclosure Rules.

(3) Prevention of Insider Trading

Regarding the prevention of insider trading, etc., the Company has formulated the Insider Trading Management Regulations to prevent insider trading. Also, in addition to conducting training on insider trading regulations for officers and employees every year, the Company obtains written pledges, etc. and strives to ensure full dissemination and thorough understanding of the regulations. As appropriate, we also provide reminders related to insider trading through internal notices.

(4) Handling of Earnings Forecasts and Forward-Looking Information

Among the earnings forecasts, future outlooks, strategies, and targets, etc. disclosed by the Company, any statement not related to past or present facts is a forward-looking statement. Such statements are formulated on the grounds of a plan, expectation, or judgment made based on information obtained by the Company at the present moment and certain assumptions deemed reasonable. Accordingly, actual earnings, etc. may differ from disclosed earnings forecasts, etc. due to fluctuations in various uncertain factors such as the economic climate.

(5) Quiet Period

From the perspective of ensuring the fairness of information disclosure and preventing the leak of earnings information (including quarterly earnings information), the Company has defined the period from the day following the fiscal year end date (or quarter end date) to the date of each earnings announcement as a quiet period. During this period, the Company shall refrain from responding to or making comments on questions related to our accounts settlement and earnings forecast. However, if the possibility of a large change in the earnings forecast arises during the quiet period, the relevant information will be announced as appropriate in accordance with the Timely Disclosure Rules.

(6) Development of Internal Systems

In accordance with this Disclosure Policy, the Company will strive to develop and enhance internal systems that allow us to disclose information in an appropriate manner pursuant to the Timely Disclosure Rules as well as laws and regulations.