Disclosure Policy

1. Basic Policy on Disclosure

We make every effort to adequately disclose information in a fair and timely manner, in order to accurately communicate management information to domestic and foreign shareholders, investors and all of our other stakeholders, and to enhance understanding of and interest in our business and management activities.

We promote our business activities according to our corporate philosophy to "creating new value" under the "transparent and sound management" of the Corporate Ethics Charter. Based on this basic policy, we will be proactive in disclosing information and IR activities, and promote the understanding of our Group, build relationships based on trust, and deepen mutual understanding to improve corporate value.

2. Criteria for Disclosure

Timely Disclosure Information as specified in the Timely Disclosure Rules of the Tokyo Stock Exchange (TSE) is disclosed in accordance with the Timely Disclosure Rules. Systematic Disclosure Information, being information whose disclosure is required by the Companies Act, the Financial Instruments and Exchange Act, or other laws and regulations, is disclosed promptly and appropriately in accordance with such laws and regulations.

Other than the above, we will be proactive in "voluntary disclosure of information" which covers decisions made by the company and events related to the company considered to have the potential impact on investment decisions by shareholders and investors, and information which influence our corporate value such as our Group achievements, products, techniques, service and etc.

3. Methods of Disclosure

We will disclose Timely Disclosure Information covered under the TSE Timely Disclosure Rules via TDnet, the disclosure service provided by TSE, in accordance with the relevant rules, as well as our website as soon as possible.

We will disclose securities reports and other disclosure documents based on Financial Instruments and Exchange Act via EDINET, the disclosure service provided by the Financial Services Agency. In the spirit of timely disclosure, we also disclose Systematic Disclosure Information and Voluntary Corporate Information, via appropriate channels such as our website.

In addition, we aim to enhance English disclosure related to IR activities in order to disclose in a fair and equitable to all domestic and foreign shareholders and investors.

4. Disclosure System

The director of the Management Planning Headquarters will be in charge of the management information disclosure of our Group. The Management Planning Department IR Promotion Office is responsible for information disclosure and IR activities, headed by a Director.

Management Planning Department IR Promotion Office will disclose the resolutions at the meeting of Board of Directors. In addition to this, IR Promotion Office will gather information and exchange opinions through meetings with each division, department, and affiliate of our group, and also deliberate with the director who is in charge of IR and the information disclosure officer for appropriate and rapid disclosure. President and CEO, management, and relevant departments will attend in IR activities with various stakeholders as needed to carry out explanations.

We hold earnings results briefings twice a year for analysts and institutional investors, as well as small earnings results briefings sponsored by securities companies, individual meetings, and conference calls for analysts and investors in accordance. We also hold briefing sessions such as directly visiting investors, especially shareholders offices, and conference calls for foreign investors based on our foreign shareholder ratio. For individual investors, we plan the business presentation and company information sessions at stock exchange and securities companies, and disclose the schedules and results on our website.

To contribute the improvement of our corporate value, we carry out shareholder surveys twice a year, and report the information obtained through the communication mentioned above to management as needed. In principle, we carry out shareholder identification twice a year to identify shareholder composition.

Our Group regulates information management such as insider information and personal information by insider trading regulation and information management regulations. In the dialogue with various stakeholders, we will disclose information fairly.

5. Silent Period

Our group set aside a two-week period prior to the announcement of our results every quarter as a "silent period," to prevent related information from being leaked and to ensure fairness. We refrain from all IR activities in relation to our results during this period. We will nonetheless respond to inquiries regarding information that has already been disclosed. We may also disclose information in accordance with the TSE Timely Disclosure Rules during the silent period, if it is deemed that the relevant information is important and could have a serious impact on investment decisions.

6. Forward-looking Statements

Earnings forecasts and estimates included in disclosed information are determined based on information available at the time of disclosure; plans and figures depicting the future do not imply a commitment or guarantee of actual outcomes. Recipients of such information are asked to understand that actual results and performance may differ from forecasts and estimates due to the effect of a variety of risks and uncertainties emerging subsequent to disclosure.

Please refer to "Terms of Use" on our website for disclaimers regarding forward-looking statements, handling of copyright and trademark rights, and use of information disclosed.

Established on May 1, 2012
1st revision on September 1, 2015
2nd revision on January 1, 2017
3rd revision on April 1, 2017
4th revision on November 1, 2017

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