5. IR policy and enhancement of disclosure and insider information control, convocation notices

10.    IR policy, enhancement of disclosure and insider information control

10.1   Basic policy for information disclosure

The Company strives to improve management transparency and trust in society by conducting fair, timely and appropriate information disclosure to shareholders, investors and other stakeholders.  Moreover, it shall proactively listen to expectations, opinions and feedback from stakeholders and reflect them in its corporate activities as necessary.

10.2   Criteria for information disclosure

The Company shall implement information disclosure in accordance with the Companies Act, the Financial Instruments and Exchange Act, other relevant laws and regulations, as well as regulations on timely disclosure prescribed by the stock exchange on which its shares are listed.  Other information not subject to relevant laws and regulations and other regulations on timely disclosure shall be positively disclosed if such information is deemed necessary for investment decisions of shareholders and investors.

10.3   Method of information disclosure

The Company shall disclose information mainly through the Electronic Disclosure for Investors’ Network (EDINET) provided by the Financial Services Agency for securities reports and other disclosure documents in accordance with the Financial Instruments and Exchange Act, Timely Disclosure network (TDnet) of Tokyo Stock Exchange or the Company’s webpages.  Moreover, English versions of documents related to earnings results announcements and other material information for disclosure are also made available at the same time from the perspective of fair and timely information disclosure.

10.4   Promotion of IR activities

The Company’s IR Division plays the central role in promoting dialogues with shareholders, domestic and overseas institutional investors and analysts based on close collaboration with relevant divisions including business units, administration divisions and group companies.  At earnings results briefing sessions, senior management directly sends clear messages on management strategy and policy, while investors and analysts are provided with opportunities for obtaining answers to their questions.  Moreover, the status of IR activities and major opinions from the capital market are provided periodically to the Board of Directors, including outside officers, through the Director in charge.

10.5   Prevention of insider trading

The Company has established Regulations on Internal Information Control and Prevention of Insider Trading and works to prevent insider trading and acts that are suspected of being insider trading or fraudulent information transmission and trade recommendations, by providing thorough internal training and appropriate control and management of insider information and trading in shares, etc.

(xi) Schematic diagram of timely disclosure framework


Schematic diagram of timely disclosure framework

10.6   Quiet period

The Company has established a “quiet period” which starts on the business day following the end of each quarter and ends on the day of announcement of quarterly earnings results for the purpose of preventing the leakage of earnings results information and ensuring compliance and fairness.
During this period, the Company refrains from answering questions regarding earnings results.  However, if the Company recognizes the possibility that actual earnings results significantly deviate from its forecasts, it shall disclose such information appropriately in accordance with rules on timely disclosure.


11.    A link to convocation notices