Disclosure Policy
1. Basic Policy on Information Disclosure
In order to achieve sustainable growth and increase in mid- to long-term corporate value, we aim to achieve honest and transparent management that can gain the trust of stakeholders, and are strengthening corporate governance and enhancing internal controls. We appropriately disclose financial information such as the company's financial condition and business performance, as well as non-financial information such as management strategies, business issues, risks in business activities, and information related to corporate governance, in accordance with laws and regulations. In addition to disclosures required by laws and regulations, we also provide information in an appropriate manner as necessary, and provide explanations and dialogue with shareholders directly or indirectly.
We have established a system to ensure that information that may have a significant impact on investment decisions is made available equally to all market participants by disclosing it in accordance with timely disclosure rules and, if necessary, posting it on our website or disclosing it to the media.
By disclosing information to shareholders and other stakeholders in a timely, proper and fair manner, we strive to enhance our credibility as a company and receive a fair valuation of our enterprise in the capital markets.
If we discover that any information previously disclosed is incorrect, we will promptly correct and disclose the error. We will also promptly update the information if there are any significant changes in circumstances.
2. Approach to dialogue
In order to achieve sustainable growth and increase in mid- to long-term corporate value, the Company recognizes that one of its important management issues is to appropriately reflect shareholder opinions in management, and the Chief Financial Officer will oversee dialogue with shareholders and investors to obtain their understanding of the Company's management strategy and management plans. In addition, by reporting opinions gained through dialogue to the Board of Directors as necessary, the Company will strive to achieve a balanced understanding of the positions of various stakeholders and to respond appropriately based on that understanding.
3. Internal system for timely disclosure of important facts
At our company, the Information Disclosure Committee, which is composed of the person responsible for handling information and the people in charge of departments related to legal disclosure and timely disclosure (finance, legal and general affairs, management promotion), will deliberate and determine the necessity of disclosing important company information, and the Board of Directors and Management Meeting will give instructions for disclosure. In addition to regular audits, the Company will receive advice and guidance from the Audit & Supervisory Board and accounting auditors. Furthermore, when deliberating and making decisions, the Company will receive advice and guidance from lawyers and other outside experts as necessary.
Information Disclosure System
4. Definition of Material Information and How to Disclose It
(1) Timely Disclosure Information
With regard to important information relating to the business, operations or performance of a company that may have a significant impact on investment decisions regarding securities and that is required to be disclosed pursuant to the timely disclosure rules established by financial instruments exchanges (such as information on decisions, occurrences and financial results relating to listed companies and subsidiaries), we will carry out disclosure procedures in accordance with the timely disclosure rules established by financial instruments exchanges, and will post such information on our website as necessary and make it public to the media.
(2) Material Information Subject to the Fair Disclosure Rules
We strive to appropriately manage undisclosed important information about the company's operations, business, or assets that may have a significant impact on investors' investment decisions, but in the unlikely event that such information is communicated to some of the parties involved in the transaction, we will disclose it in accordance with the Fair Disclosure Rules (Article 27-36 of the Financial Instruments and Exchange Act and the Cabinet Office Ordinance on Disclosure of Material Information). If necessary, we will post the information on our website and disclose it to the media.
(3) Legal disclosure information
We will disclose important information that is required to be disclosed statutorily under the Financial Instruments and Exchange Act in an appropriate manner in accordance with the law. If necessary, we will post such information on our website and make it public to the media.
5. Preventing insider trading
In order to properly manage important information and prevent insider trading, the Company has established internal regulations and is promoting awareness-raising activities and thorough dissemination of these regulations throughout the Group.
6. Improving fairness in access to information
In order to provide investors with fair access to timely disclosure, the Company will disclose information on its website in addition to filings with each stock exchange and issuing press releases, all of which will be done at the same time.
If a spokesperson designated by the Company unintentionally discloses important non-public information at an investor briefing or other event, the Company will promptly make a timely disclosure of that information. Similarly, if important non-public information that should be disclosed in a timely manner is disclosed by a third party prior to the Company's disclosure, the Company will promptly make a timely disclosure of that information.
7. Quiet Period
In order to prevent the leaking of financial information, the Company will observe a quiet period from the day after the closing date of this fiscal year and each quarter until the announcement of the financial results, during which time the Company will refrain from making any new comments related to financial information. However, if there are any prospects during this period that are significantly different from the previous performance forecast, the Company will disclose such information in accordance with the timely disclosure rules. However, even during the quiet period, the Company will respond to inquiries regarding information that has already been made public.
8. Future outlook
The plans, future prospects, strategies, etc. of the Group published in our disclosure materials, other than those related to past or present facts, are forecasts of future performance and are based on the judgments and assumptions of our management team using information currently available to us. Therefore, actual performance may differ significantly due to uncertainties, economic conditions, and other risk factors.
In principle, we will not comment when a third party expresses an opinion about our future plans. However, if there is an obvious factual error or mistake in the third party's comment, we may point it out on our website.
9. Responding to market rumors
We do not comment on market rumors, either confirming or denying them.
When rumors or reports circulating about our company are deemed to have a significant impact on the capital markets and it is necessary to clarify the truth of the matter, we will appropriately disclose the information through the Timely Disclosure Network (TDNet) or other means.