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Disclosure Policies
1. Criteria for information disclosure
We will promptly disclose information and maintain transparency, fairness, and continuity in accordance with the provisions of laws such as the Financial Instruments and Exchange Act, and the rules for listing securities as prescribed in the Tokyo Stock Exchange's "Timely Disclosure of Corporate Information, etc." (hereinafter the "timely disclosure rules"). We will also proactively and fairly disclose information that we find important or beneficial for giving stockholders and investors a better understanding of us, even when doing so is not required under various laws and the timely disclosure rules. Furthermore, we will not disclose personal information, customer information, and information that could violate the rights of our associates.
2. How the information will be disclosed
We will disclose the information governed by the timely disclosure rules through TDnet (the Tokyo Stock Exchange's timely disclosure information transmission system), and disclose the information for which disclosure is legally required under the Financial Instruments and Exchange Act through EDINET (Electronic Disclosure for Investors' NETwork: an electronic disclosure system for documents, including securities reports, to be disclosed in accordance with the Financial Instruments and Exchange Act) and publish such information on our website promptly after releasing it through those systems. In addition, we will widely disclose information that we consider important or beneficial by publishing it on our webpage, even if such information is not governed by the timely disclosure rules.
3. Preventing inside trading
To prevent insider trading, we have formulated internal information control rules. We also ensure that our board members and employees fully understand the meaning and intent of the insider trading regulations through study annual sessions on them. In addition, we release internal notices on insider trading as appropriate to our board members and employees.
4. Handling of information on performance forecasts and future prospects
From among performance forecasts, future prospects, strategies, targets, etc., all except those based on present or past facts are statements about future prospects, based on plans, expectations and decisions derived from information currently in our hands as well as certain assumptions that are considered rational. Therefore, actual performance etc., may vary from the disclosed performance forecasts, future prospects etc., due to fluctuations in uncertain factors such as economic conditions.
5. Silent periods
To prevent information about financial results (including quarterly financial statements) from leaking and to ensure the fairness of information disclosure, we set a silent period from the day after the last day of the fiscal term (the date the quarterly financial statements are closed) to the day the financial statements are announced. During this period, we refrain from replying to or commenting on questions to us about our financial statements and performance forecast. However, we will make announcements as appropriate according to the timely disclosure rules if our performance forecast is likely to differ considerably during this period.