Company’s Basic Stance on Timely Disclosure

The Company’s basic stance is to disclose corporate information in a timely and appropriate manner, which may have a significant impact on the decisions of our investors, and the Company has always strived to do so.

The Company has established “Insider Information Management Rules,” which are company rules for the purpose of preventing insider trading by officers and employees and ensuring thorough information management and timely and appropriate disclosure. The Company has been making efforts to comply with the Financial Instruments and Exchange Act and other related laws and regulations.

Internal System for Timely Disclosure of Corporate Information

The Company has designated the Public Relations Div. as the division in charge of managing information (Person in charge of managing information: the Senior General Manager of the Public Relations Div.). In accordance with the above-mentioned Insider Information Management Rules and the Publicity Handling Rules, the Company will disclose corporate information in a timely and appropriate manner under the following system.

Aggregation of Corporate Information and Determination of Timing of Disclosure

Important corporate information about the Company’s Business Groups, Administration Divisions, and major subsidiaries will be immediately reported to the Public Relations Div.
The Public Relations Div. will determine the necessity of timely disclosure of information in accordance with the Timely Disclosure Rules of the Tokyo Stock Exchange and other relevant rules.

Timely Disclosure of Corporate Information

If timely disclosure is determined to be necessary, the Public Relations Div. will disclose corporate information in a timely manner upon request of the Executive Officer in charge of such disclosure.
With respect to timely information disclosure, the Company will comply with the Financial Instruments and Exchange Act and other related laws and regulations, as well as the Insider Information Management Rules, to strictly manage internal information. Disclosure requiring review from a company-wide perspective will be examined by the Information Disclosure Committee, which is chaired by the Executive Officer in charge of public relations and comprised of the heads and other individuals of Corporate Management Divisions.
Matters requiring a resolution at the Executive Officers’ meeting or the Board of Directors’ meeting will be timely disclosed after discussion and approval.

Internal Timely Disclosure System Overview