Disclosure Policy

Basic stance for disclosure of information

The Company will strive to ensure the timeliness, transparency, fairness, and continuity in disclosing information on management policies, business strategies, business results, and financial affairs of the Company to shareholders, investors, and other stakeholders.

Standards for disclosure of information

The Company will disclose corporate information in a timely and appropriate manner in accordance with the statutory disclosure systems under the Financial Instruments and Exchange Act and the Securities Listing Regulations provided for by the Tokyo Stock Exchange (hereinafter the “Timely Disclosure Rule”). The Company discloses even information that does not fall within the scope of statutory disclosure system nor the Timely Disclosure Rule in a proper and fair way, if it judges the information is likely to affect the investment decisions of shareholders and investors or useful for stakeholders to understand the business, products and technology of the Company. The Company will not selectively disclose any specific information only to specific persons, except for general information on our products and technology. The Company will also not disclose any personal information, customer information, or information wherein such disclosure would infringe the rights of the relevant persons or is not permitted contractually.

Method of information disclosure

The Company will disclose information through the Electronic Disclosure for Investors' NETwork, an electronic disclosure system, (hereinafter “EDINET”) provided for financial statements by the Financial Services Agency under the Financial Instruments and Exchange Act and other relevant laws, registrations and rules legislation, the Timely Disclosure network, a timely information disclosure transmission system, (hereinafter “TDnet”) provided by the Tokyo Stock Exchange, or by other means as appropriate. Information disclosed through EDINET and TDnet will be promptly published on the website of the Company by giving attention to the timeliness and fairness of the information. However, for reasons attributable to the systems, publication of such information on the website of the Company may be delayed.
The Company may disclose other information by publication on our website or by other means depending on the contents of the information. While information is disclosed in Japanese, the Company will strive to disclose important information translated into English to enable communication with more stakeholders.

Quiet period

To prevent leakage of the material information and ensure the fairness, the Company has established a quiet period beginning from the day following the end of each quarter to the quarterly announcement of financial results. During that period, the Company will refrain any comments and answers to inquiries about the financial results and any new comments that are different from the information disclosed regarding the last financial results. However, if during that period, there is any fact subject to timely disclosure, the Company will disclose it, as appropriate, pursuant to Timely Disclosure Rule manner. Even during a quiet period, the Company will respond to inquiries about information that is already disclosed.

About predictions for the future

Please note that an business forecasts and future prospects relating to business strategies, research, and development disclosed by the Company are made based on information that is available at the time of preparation and involve risks, known or unknown, and uncertain factors in the forecast stage and may be subject to material change due to various factors, including future fluctuations in the economic situation and market environment. The Company will not support any comments or business forecasts whatsoever that are provided by a third party regarding the Company.

Prevention of insider trading

To prevent insider trading, the Company stipulates codes that should be complied with regarding proper control of insider information and stock trading, and the Company will implement those codes appropriately. The Company will limit information to be disclosed within our company information sessions, answers to telephone inquiries and media interviews to such information that has been already made public by the Company, and will not comment on any material facts not yet open to the public.

Information disclosure system

The Company designates the Finance and Accounting Department as the department in charge of investor relations and will disclose information under the director of the Administration Division as the information administrator. The Company sets out the procedure for timely disclosure in internal regulations that conform to the spirit of the statutory disclosure systems and the Timely Disclosure Rule, and the Company will, in accordance with such procedure, promptly make timely disclosure through the necessary procedures.

Efforts toward improvement of IR activities

For the sustainable growth of the Company and maximization of mid- to long-term corporate value, the Company recognizes the importance of making efforts to obtain understanding from and work with stakeholders through communications. Based on such recognition, the president and other executives will provide, in addition to information disclosure through EDINET and TDnet, explanations of the present condition of the Company and mid- to long-term business strategies on the occasions of company information sessions for institutional investors/analysts, those for individual investors, and individual meetings with institutional investors. Constructive opinions obtained through such communications will be fed back to the board of directors and executives and will be used effectively in efforts toward the creation of mid- to long-term strategies and corporate value. Outside those occasions, the Company will accept and respond to individual inquiries, as a rule, not orally but in writing (mails) because the Company needs to provide fair and accurate information.