Disclosure Policy

1.Information Disclosure Standards

The Company has the intention to promptly disclose the information in conformity with the provisions stipulated in the relevant laws and regulations such as the Financial Instruments and Exchange Law, and the Rules on "Timely Disclosure of Company Information" (hereinafter "Timely Disclosure Rules") in the Securities Listing Regulations provided for by Tokyo Stock Exchange, to make sure the transparency, fairness and continuity should be maintained. Even if any laws and regulations, or the Timely Disclosure Rules are not applicable, we are willing to disclose the information in actively and impartially that we think that is important or helpful for the shareholders and the investors to understand our company. Please note, however, that we shall not disclose any personal information, client-related information, and any information damaging and infringing the rights of our related parties.

2.Information Disclosure Methods

As for the information disclosure under the Timely Disclosure Rules, we shall disclose the information in accordance with the Rules through the Timely Disclosure Network (TDnet), provided by Tokyo Stock Exchange, and put up the same information on this website immediately after the disclosure through TDnet. Even if the Timely Disclosure Rules are not applicable, we shall disclose the information on this website that we think that is important or helpful.

3.Prevention of Insider Trading

The Company has internally established the information management rules and the insider trading management rules to prevent from occurring insider trading. In addition, The Company makes it a rule to hold the study workshops about the insider trading regulations for our officers and the employees every year, and furthermore distribute the explanatory materials for them to read. The Company has tried not only to make them thoroughly understand the subject matter of these activities and but also to draw attention from them to the insider trading by the internal notification in a timely manner.

4.Handling of Earnings Forecast and Future Information

Among the information about the earnings forecast, future outlook, business strategies, target, etc, disclosed by our company, it should be the written statement about the future outlook if it is not about the past or present fact, based on the information currently available to us, and plans, expectations and judgment in accordance with certain preconditions that we think reasonable. Therefore, the actual business results may be different from the earnings forecast disclosed in advance, due to uncertain variables such as the economic situation, etc.

5.Quiet Period

In order to avoid information leakage about business results (including the quarterly business results information), and at the same time to ensure fair information disclosure, we have established a rule to not disclose any information during the period commencing from the day following each quarterly end of the fiscal year (quarterly business results) until the day when we announce the actual business results. During this quiet period, we shall refrain from answering to questions on business results and earnings forecast, or making comments on it. If during this quiet period, however, there is anything that is likely to change the earning forecast dramatically, we shall choose to disclose the necessary information in a timely manner in conformity with the Timely Disclosure Rules.

6.Development of Internal Systems

The Company has tried to organize and strengthen the internal disclosure system in order to make the proper disclosure in accordance with our disclosure policy, and according to the relevant laws and regulations and the Timely Disclosure Rules.