Corporate Structure and Procedures with Regards to Timely Disclosure of Corporate Information
Our corporate structure and procedures with regards to the timely disclosure of corporate information is as follows.
1. Regarding timely disclosure policy
Our corporate philosophy is “We will grow and develop globally as a systems builder and continue our contribution to people and community.” Besides, we have “compliance manual” in which we fully understand the purpose of Insider Trading Restrictions, and prescribe the strict compliance with rules as for handling important information’s. Our company provides timely disclosure under the basic policy which requests us to observe laws, and do fair and transparent corporate activities under social norms and corporate ethics.
Specifically, we provide disclosure in compliance with “Timely disclosure rules and other regulations for issuers of listed negotiable securities or valuable instruments” (hereinafter called "Timely disclosure rules") of the Tokyo Stock Exchange, also we will try to actively and promptly disclose company information that we consider disclosure is effective and valuable for understanding our company, even if there is no obligation to disclose.
2. Corporate structure for receiving and managing timely disclosure information and disclosing it properly and timely.
(1) Information of decided matters
Administration headquarters provide timely disclosure after the approval of the board of directors or executive committee, with internal consultation about the necessity of disclosure and the contents of the disclosed information, and with prior notification to the Tokyo Stock Exchange if needed.
(2) Information of occurrence matters
Administration headquarters provide timely disclosure in compliance with timely disclosure rule after reporting from the department which recognizes the occurrence of the incidences to the board of directors or executive committee.
If an urgent matter occur, a department which recognizes the occurrence of the incidences directly reports to administration headquarters, and they have a consultation with related department and provide timely disclosure.
(3) Financial information
Financial information is which is prepared by financial department and audited by external auditors disclosed by administration headquarters after the approval of the board of directors.
If an emergency matter such as revising forecasts occurs, administration headquarters provide timely disclosure after a consulting with the director in charge.
(4) Information of subsidiaries
As for the information of subsidiaries, proper department of subsidiaries reports it to the administration headquarters, and they have a consulting with related department, and provide timely disclosure after the approval of the Board of Directors if needed.
3. Timely disclosure check monitoring
Auditors do monitoring and verification about the cooperate structure for properly and timely disclosing of corporate information according to “Audit of cooperate structure for corporate information disclosure” in “Internal auditing standards”.
4. Initiatives for the prevention of insider trading
Besides managing to disclose the information properly and timely according to timely disclosure rules, our company makes all possible efforts to manage properly the corporate information and prevent of insider trading.
Our company has internal rules which prescribe even if any directors or employees get the information of the important incidents of the company or any other company, they must not disclose it until the matters are published.
Stock administrator makes sure whether it is not insider trading prior to buying or selling of our company stock by an director or employee.（If it is applicable, the trading is restricted until the release of important incidents.）
5. In-house training
In order to educate employees for having better recognition of the importance of the disclosure and the prevention of insider trading, we set up the education system with holding seminars by external instructors.
In-house structure scheme related to timely disclosure.
