- Disclosure Policy
1. Standard of Information Disclosure
We have the intention to promptly disclose the information in conformity with the provisions stipulated in the relevant laws and regulations such as the Financial Instruments and Exchange Law, and the Rules on Timely Disclosure of Corporate Information by Issuers of Listed Securities in the Securities Listing Regulations provided for by Tokyo Stock Exchange (hereinafter referred to as "Timely Disclosure Rules", to make sure the transparency, fairness and continuity should be maintained. Even if any laws and regulations, or the Timely Disclosure Rules are not applicable, we are willing to disclose the information in an equitable manner that we think that is important or helpful for the shareholders and the investors to understand our company. Please note, however, that we shall not disclose any personal information, client-related information, and any information damaging and infringing the rights of our related parties.
2. Method to Disclose the Information
As for the information disclosure under the Timely Disclosure Rules, we shall disclose the information in accordance with the Rules through the Timely Disclosure Network (TDnet), provided by Tokyo Stock Exchange, and put up the same information on our official website immediately after the disclosure through TDnet. Even if the Timely Disclosure Rules are not applicable, we shall disclose the information on our official website that we think that is important or helpful.
3. Prevention of Insider Trades
We have internally established the information management rules and the insider trade management rules to prevent from occurring insider trades. In addition, we make it a rule to hold the study workshops about the insider trade regulations for our officers and the employees every year, and further more distribute the explanatory materials for them to read. We have tried not only to make them thoroughly understand the subject matter of these activities and but also to draw attention from them to the insider trades by the internal notification in a timely manner.
4. Earnings Forecast and How to Handle the information about the future
Among the information about the earnings forecast, future outlook, business strategies, target, etc, disclosed by our company, it should be the written statement about the future outlook if it is not about the past or present fact, based on the information currently available to us, and plans, expectations and judgment in accordance with certain preconditions that we think reasonable. Therefore, the actual business results may be different from the earnings forecast disclosed in advance, due to uncertain variables such as the economic situation, etc.
5. Quiet Period
In order to avoid information leakage about business results (including the quarterly business results information), and at the same time to ensure fair information disclosure, we have established a rule to not disclose any information during the period commencing from the day following each quarterly end of the fiscal year (quarterly business results) until the day when we announce the actual business results. During this quiet period, we shall refrain from answering to questions on business results and earnings forecast, or making comments on it. If during this quiet period, however, there is anything that is likely to change the earning forecast dramatically, we shall choose to disclose the necessary information in a timely manner in conformity with the Timely Disclosure Rules.
6. Organizing the Internal Disclosure System
We have tried to organize and strengthen the internal disclosure system in order to make the proper disclosure in accordance with our disclosure policy, and according to the relevant laws and regulations and the Timely Disclosure Rules.
The earnings forecast, plans, strategies and so on of our company indicated on our official website are the outlook related to our future business operations including risks and certainties, that the management of our company decides to be appropriate based on currently available information. Please be advised that the actual business results may be different from the earnings forecast due to the economic situation, market trend and so on surrounding our business. No information is indicated on our official website for the purpose of soliciting people to buy or sell our shares or so. Please make investment decisions based on your own judgment. We may change the contents on our official website or suspend its indication at any time without prior notification. There may be some situations where you cannot use our website correctly due to unexpected issue in the telecommunication environment, or the odd situation of your computer, or any other reason. We shall not be responsible for any obstacle or damage rising out of errors or mistakes in the contents on our website, or data manipulation made by any third party, or data downloading from our website.