Disclosure Policy

1. Information disclosure standards

The Company strives to carry out information disclosure grounded in transparency, fairness, and continuity in compliance with the Financial Instruments and Exchange Act, and other related laws and regulations, as well as rules on the timely disclosure of corporate information stipulated in the "Securities Listing Regulations" of the Tokyo Stock Exchange (hereinafter the "Timely Disclosure Rules").　Furthermore, the company will proactively and fairly provide information we deem important or valuable to shareholder or investor understanding of our company even when not required by relevant laws or “Timely Disclosure Rules”.

We will not, however, disclose personal information, client information, or information that would infringe upon the rights of a related party.

2. Information disclosure methods

Information subject to the “Timely Disclosure Rules” is promptly disclosed via the Timely Disclosure Network (TDnet) provided by Tokyo Stock Exchange and shortly thereafter published on our corporate website. Information that is not subject to the “Timely Disclosure Rules” but that we deem important or valuable is also disclosed through publication on our corporate website.

3. Prevention of Insider Trading

The company has established internal rules for the management of information and insider trading in order to prevent insider trading. Additionally, each year the company conducts a study session on insider trading regulations for both officers and employees and distributes explanatory materials in order to promote thorough understanding of these rules. Additionally the Company sends appropriate internal communications to raise aware awareness of these rules.

4. Handling of Financial Forecast and Information Concerning the Future

Any facts that are neither historical nor current that are disclosed in our financial forecasts, future predictions, strategies, targets, etc., are forward-looking statements. Such statements are made on the grounds of a plan, expectation, or decision made based on information in the possession of the firm at the time and certain assumptions deemed reasonable. Thus, actual financial results may vary greatly to our disclosed financial forecast due to economic conditions as well as various other uncertainties and risk factors.

5. Quiet Period

In order to ensure fair disclosure and prevent leaks of financial results information (including quarterly financial results information), The Company has set a quiet period from the day after the end of a fiscal year (or quarter) until the announcement of the financial results. During this period, The Company will refrain from responding to questions or making comments related to our financial results and forecasts. However, if, during the quiet period, we come to predict a large discrepancy from the earnings forecast, information will be disclosed in an appropriate and timely manner in accordance with “Timely Disclosure Rules”.

6. Establishment of an Internal Structure

Based on this Disclosure Policy, the Company strives to establish and enhance our internal structure in order to conduct appropriate information disclosure, in accordance with various laws and regulations and the “Timely Disclosure Rules”.