IR Policy

Disclosed information

The Company shall disclose information timely and appropriately in accordance with related laws such as the Financial Instruments and Exchange Act and timely disclosure regulations specified by the Tokyo Stock Exchange, and shall endeavor to ensure that all market participants can equally acquire important information that affects investment decisions. Information judged to be effective for understanding the Company that does not apply to disclosure regulations shall be actively disclosed in a timely manner.

Method of disclosing information

When disclosing information based on the Companies Act and Financial Instruments and Exchange Act, it shall be disclosed properly by public notice based on the said laws or by submitting an annual securities report. In addition, when disclosing information based on timely disclosure regulations, this shall be disclosed by using TDnet^*1 pursuant to the said regulations or via the Company’s website.^*2

The Company shall disclose information that does not correspond to this by an appropriate method based on the aims of timely disclosure. This disclosure shall be made in a fair and equitable manner.

• TDNet is the information disclosure network system of the Tokyo Stock Exchange.
  (URL：https://www.release.tdnet.info/index.html)
• When disclosing information via a website, it may be later than the disclosure period by TDNet due to converting the data to a PDF file or preparing the web file.

Prevention of insider trading

Investors that have received vital information directly from a company (primary information recipient) are prohibited from trading shares prior to the said information being “announced” (Article 166 of Financial Instruments and Exchange Act).

The 12-hour rule relating to this “announcement” was partly revised on February 1st, 2004 (Article 30 of the Enforcement ordinance of the Financial Instruments and Exchange Act). When vital information is registered in TDnet for public inspection on the TDnet website, this completes the “announcement” step. In accordance with this revision, since February 1st, 2004, the Company has been disclosing vital information on our own website after confirming that it has been registered in TDnet for public inspection.

Setting a quiet period

To prevent leakage of financial accounts information and ensure fairness, an “IR activities quiet period” is set from the day following the financial accounts end (including the quarter) to the period before the announcement of financial accounts. During this period, we withhold answers to questions and comment regarding financial accounts. However, if it is foreseen during this quiet period that earnings forecasts are considerably out of line, this will be publicly announced in accordance with disclosure regulations. Despite this quiet period, we will answer questions relating to information already made public.