Disclosure Policy
The Company hereby establishes the following basic policy regarding information disclosure and shall practice appropriate disclosure in order to build long-term relationships of trust with all stakeholders, including shareholders and investors in Japan and overseas.
1.Basic Policy on Information Disclosure
The Company shall endeavor to provide shareholders, investors, and all other stakeholders with prompt and accurate disclosure of financial information, including the Company’s financial position and operating results, as well as non-financial information, including management strategies, management issues, risks, and governance-related matters, based on the principles of transparency, fairness, and continuity.
In making disclosures, the Company shall comply with the Fair Disclosure Rule as set forth in the Financial Instruments and Exchange Act, and shall take due care to avoid selective disclosure to any particular parties. The Company shall also endeavor to ensure fair information disclosure.
2.Standards for Information Disclosure
The Company shall comply with the Financial Instruments and Exchange Act and other applicable laws and regulations, as well as the Securities Listing Regulations (the “Listing Regulations”) prescribed by the Stock Exchange on which the Company’s shares are listed, and shall make disclosures in accordance therewith. In addition, even where certain information does not fall within the scope of the timely disclosure standards prescribed by applicable laws and regulations and the Listing Regulations, the Company shall disclose such information, taking into consideration fairness and timeliness, if it is deemed to have a material impact on investment decisions. Notwithstanding the foregoing, the Company shall not disclose any personal information, customer information, or any information that may infringe upon the rights of any related parties.
3.Methods of Information Disclosure
The Company shall take due care to ensure that (i) material information required to be disclosed pursuant to applicable laws and regulations and the Listing Regulations, and (ii) information that does not fall within the timely disclosure standards prescribed therein but is deemed likely to have a material impact on investment decisions, is communicated accurately and fairly through appropriate methods, depending on the materiality and urgency of such information.
With respect to material information that the Company determines should be disclosed, the Company shall disclose such information through TDnet (Timely Disclosure Network), the timely disclosure information transmission system provided by the Tokyo Stock Exchange, in accordance with the timely disclosure standards prescribed by applicable laws and regulations and the Listing Regulations, and, in principle, shall promptly post the same information on the Company’s website. In addition, even where certain information does not fall within the timely disclosure standards prescribed by applicable laws and regulations and the Listing Regulations, the Company shall post such information on the Company’s website, depending on the materiality and urgency of such information, if it is deemed likely to have a material impact on investment decisions.
4.Quiet Period
In order to prevent leaks of financial results information and to ensure fairness, the Company has designated the period from the day following each financial closing date (meaning each quarterly closing date and the fiscal year-end closing date) until the date of announcement of the financial results for such period as the “Quiet Period.” During the Quiet Period, the Company shall refrain from providing comments on financial results, responding to questions regarding financial results, and responding to media inquiries. The Company shall also refrain from holding one-on-one meetings with analysts and institutional investors, regardless of the content thereof. Notwithstanding the foregoing, if any material information requiring disclosure arises during the Quiet Period, the Company shall publicly disclose the necessary information in accordance with the timely disclosure standards prescribed by applicable laws and regulations and the Listing Regulations.
5.Performance Outlook and Forward-Looking Statements
The Company may disclose or comment on forward-looking information, including outlooks and strategies related to future performance. Such information shall be based on the judgment of the Company’s management team using information available at the time, and the Company does not guarantee the reasonableness or accuracy thereof. Accordingly, actual results may differ materially due to uncertainties, economic conditions, and other risk factors.
6.Development and Enhancement of Internal Systems
In order to operate this Disclosure Policy appropriately and to enhance stakeholders’ understanding of dialogue with the Company, the Company shall endeavor to develop and enhance a cooperative framework among the relevant departments. The Company has also established internal rules regarding the management of insider trading and, in order to ensure strict compliance therewith, focuses on providing education and training to its directors, officers, and employees.
7.Disclaimer
The information posted on the Company’s website is provided solely for the purpose of helping readers understand the Company’s financial and management information and is not intended to solicit investment. Any investment decisions shall be made at the reader’s own discretion and responsibility.
Adopted January 16, 2026

