Disclosure Policy

(1) Criteria for disclosure

In accordance with the Financial Instruments and Exchange Act and other laws and regulations, as well as the Rules on Timely Disclosure of Corporate Information, etc. (hereinafter referred to as “Timely Disclosure Rules”) of the Securities Listing Regulations established by the Tokyo Stock Exchange, we disclose information promptly in the interests of transparency, fairness, and continuity. Even in cases not covered by laws and regulations or the Timely Disclosure Rules, we actively and fairly disclose information that we deem important or useful for shareholders and investors to understand the Company. We do not disclose personal information, customer information, or information that may infringe on the rights of related parties.

(2) Methods of disclosure

Information required by the Timely Disclosure Rules are disclosed through the Timely Disclosure Network (TDnet) provided by the Tokyo Stock Exchange in accordance with the Rules and are promptly posted on the Company’s website after being disclosed through TDnet. Information not covered by the Timely Disclosure Rules but deemed important or useful is disclosed by posting on the Company’s website.

(3) Prevention of insider trading

To prevent insider trading, we have established Information Management Regulations and Insider Trading Management Regulations. In addition, we conduct a study session on insider trading regulations for officers and employees every year, distribute explanatory materials to ensure thorough understanding and awareness of the regulations, and issue internal notices as appropriate to alert the appropriate persons to insider trading.

(4) Handling of earnings forecasts and other future-oriented statements

Forward-looking statements are statements other than those relating to past or present facts. They are grounded in plans, expectations and judgments based on information currently available to the Company and certain assumptions that the Company judges to be reasonable. Actual results may differ from the disclosed forecasts, etc., due to variable factors such as economic conditions and other uncertainties.

(5) Silent period

To prevent leakage of financial information (including quarterly financial information) and ensure the fairness of information disclosure, the Company designates the period from the day following the end of the fiscal year (quarterly financial results) to the day of each earnings announcement as a silent period. During this period, we refrain from answering questions or commenting on financial results and forecasts. However, if we anticipate a significant change in our earnings forecast during this period, we will make an appropriate public announcement in accordance with the Timely Disclosure Rules.

(6) Development of internal systems

In accordance with this Disclosure Policy, the Company is striving to develop and enhance its internal systems to ensure appropriate disclosure of information in accordance with various laws and regulations and timely disclosure rules.