Disclosure Policy

1. Information Disclosure Standards

The Company will promptly disclose information based on transparency, equitability and continuity in accordance with laws and regulations such as the Financial Instruments and Exchange Act and the “Rules on Timely Disclosure of Corporate Information” (hereinafter the “Timely Disclosure Rules”) in the Securities Listing Regulations set forth by the Tokyo Stock Exchange. The Company will also proactively and im partially disclose information that it regards as important or useful in enabling shareholders and investors to understand the Company, even if it does not fall under a case stipulated in the laws and regulations and the Timely Disclosure Rules. However, the Company will not disclose personal information, customer information or information that could be detrimental to the rights of the persons concerned.

2. Method of Information Disclosure

The Company will disclose the information required by the Timely Disclosure Rules through the Timely Disclosure network (TDnet) provided by the Tokyo Stock Exchange in accordance with the Timely Disclosure Rules. After disclosing the information, the Company will immediately post it on its website. The Company will also widely disclose information that is not required by the Timely Disclosure Rules by posting it on its website, among other methods, if the Company regards it as important or useful.

3. Prevention of Insider Trading

The Company prevents insider trading by establishing information management regulations and insider trading management regulations. The Company also makes efforts to keep its officers and employees informed of the purport of the insider trading regulations and promote their understanding by holding a workshop on the insider trading regulations every year. The Company also draws their attention to insider trading through an internal notification whenever appropriate.

4. Handling of Results Forecasts and Future Information

Of results forecasts, future prospects, strategies and objectives, etc. disclosed by the Company, those other than those related to the past and the present are forward-looking statements, and these statements are made on the grounds of plans, expectations and judgments based on information currently available to the Company and certain assumptions that are deemed reasonable. As a result, actual results, etc. could differ from the disclosed results forecasts, etc. due to various uncertainties and variable factors such as the economic conditions.

5. Silent Period

The Company has set the period from the day following the last day of a fiscal year (a quarter) to the day of the results announcement as a silent period from the standpoint of preventing financial information for the fiscal year (including financial information for the quarter) from begin leaked and securing the equitability of information disclosure. We have decided to refrain from answering questions and making comments on financial results and results forecasts during the stilent period. However, if it becomes likely that our results forecasts will change significantly during this period, we will disclose this whenever appropriate in accordance with the Timely Disclosure Rules.

6.Development of the Company Structure

The Company is striving to develop and enhance its structure to make appropriate information disclosure in compliance with the laws and regulations and the Timely Disclosure Rules according to this Disclosure Policy.