DISCLOSURE POLICY

(1) Information Disclosure Standards

The Company will disclose information promptly based on the principles of transparency, fairness, and continuity, in accordance with the Financial Instruments and Exchange Act and other laws and regulations, as well as the “Timely Disclosure of Corporate Information” provisions of the Securities Listing Regulations established by the Tokyo Stock Exchange (hereinafter referred to as the “Timely Disclosure Rules”). Furthermore, even when not required by laws and regulations or the Timely Disclosure Rules, we will proactively and fairly disclose information deemed important or beneficial for shareholders and investors to understand our company. Additionally, from the perspective of fair information disclosure, if material information (unpublished material facts, etc., and definitive financial results information prior to publication that could significantly impact stock prices) is unintentionally communicated to specific investors, analysts, or others, we will, in principle, promptly disclose such information. However, we will not disclose information that infringes on personal information, customer information, or the rights of related parties.

(2) Methods of Information Disclosure

Disclosures required under the Timely Disclosure Rules will be made through the Timely Disclosure Network (TDnet) provided by the Tokyo Stock Exchange, in accordance with those rules. After disclosure via TDnet, the information will be promptly posted on our company website. Even for information not falling under the Timely Disclosure Rules, we will widely disclose information deemed important or beneficial through means such as posting on our company website.

(3) Prevention of Insider Trading

To prevent insider trading, we have established Information Management Regulations and Insider Trading Management Regulations. Furthermore, we hold annual study sessions for officers and employees on insider trading regulations, distribute explanatory materials, and strive to thoroughly communicate and promote understanding of their purpose. We also issue internal notices as appropriate to raise awareness regarding insider trading.

(4) Handling of Earnings Forecasts and Forward-Looking Information

Among the earnings forecasts, future outlooks, strategies, targets, etc., disclosed by the Company, any statements not based on past or present facts constitute forward-looking statements. These are based on plans, expectations, and judgments derived from information currently available to the Company and certain assumptions deemed reasonable. Therefore, actual results may differ from disclosed forecasts due to various uncertain factors, including changes in economic conditions.

(5) Quiet Period

To prevent leaks of financial results information (including quarterly results) and ensure fairness in information disclosure, the Company has designated the period from the day following the end of each fiscal quarter (or fiscal year) to the date of the respective earnings announcement as a quiet period. During this period, the Company refrains from responding to or commenting on questions regarding financial results or performance forecasts. However, should significant changes to the performance forecast become foreseeable during this period, the Company will disclose such information promptly in accordance with the Timely Disclosure Rules.

(6) Establishment of Internal Systems

The Company strives to establish and enhance its internal systems to ensure appropriate information disclosure in compliance with laws, regulations, and the Timely Disclosure Rules, in accordance with this Disclosure Policy.