Group Disclosure Policy

1. Basic policy on information disclosure

The Company has formulated the Group Disclosure Policy as part of promotion activities for compliance in laws and regulations and corporate governance regarding information disclosure, and discloses to shareholders and investors critical information on matters decided, material facts occurred or financial results that may influence investment judgment in accordance with the Financial Instruments and Exchange Law, other laws and regulations as well as with the Timely Disclosure Rules set out by the Tokyo Stock Exchange.
The Company also discloses information outside the scope of material facts defined by the law and regulations including the Timely Disclosure Rules, and that are deemed helpful to shareholders and investors, in a timely and fair manner to the extent possible.

2. Methods of information disclosure

Information subject to the Timely Disclosure Rules is disclosed through the Timely Disclosure Network (TDnet) operated by the Tokyo Stock Exchange in compliance with the Rules. As soon as it is registered on the TDnet, the same material is made public on the Company's website.
For the purpose of preventing insider trading, information that is not subject to the Timely Disclosure Rules or other provisions, and that the Company believes will influence investment judgment, is disclosed in the fairest possible manner by appropriate methods according to the level of importance and urgency, for example by making such information available on the TDnet and disclosing it on the Company's website immediately thereafter.

3. Quiet period

To prevent any leak of information on financial results, including interim and quarterly results, or any other information that may influence the share price, and to ensure fairness, the Company observes a quiet period from the business day after the closure of a fiscal period until the day of the announcement of the financial results. During this period, the Company refrains from responding to inquiries or commenting on financial results or earnings forecasts. However, in the event that the financial results confirmed during the quiet period differ so substantially from previously announced earnings forecasts that the disparity is likely to be subject to the Timely Disclosure Rules, the Company discloses the information in an appropriate manner in accordance with the Rules.

4. Information disclosure to a third party and earnings forecasts by a third party

The Company discloses information in a fair manner to the public, without distinction of persons, for example to institutional investors, analysts, individual investors and the media, and if any error is found in information previously disclosed, the Company promptly corrects the error and discloses the details of it. Furthermore, if a substantial change occurs in information previously disclosed, the Company promptly revises the information and discloses the details of it.
The Company endorses no comment, earnings forecasts or suchlike with regard to the Company made by any third party.

5. Spokespersons for investor relations activities

To ensure the accuracy of information and fairness of disclosure, the Company designates its President and CEO, the director responsible for IR, and IR personnel, as the spokespersons for the Company's principal IR activities. In principle, no employee or officer who is not a spokesperson independently offers information relating to the Company to any party associated with the securities market or with the media. Where necessary, spokespersons may appoint any other employee or officer to act as a proxy.

December 25, 2018