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Timely Disclosure of Corporate Information

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 are as follows.

1. 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. Our company makes timely disclosure under the basic policy which requests us to observe laws, and do fair and transparent corporate activities in the context of social norms and corporate ethics.

Specifically, we implement 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 gathering and managing timely disclosure information and disclosing it properly and timely.

(1) Information of decided matters

Administration headquarters make 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 information to be disclosed, and with prior notification to the Tokyo Stock Exchange if needed.

(2) Information of occurrence matters

Administration headquarters make 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.

In case of emergency, the relevant department directly reports to administration headquarters, and they have a consultation with related department and the director in charge before making timely disclosure.

(3) Information of financial results

Information of financial results is which is prepared by administration headquarters and audited by external auditors, then disclosed by administration headquarters after the approval of the board of directors.

In case of emergency such as revise of earnings forecast, administration headquarters make timely disclosure after a consulting with the director in charge.

(4) Information of subsidiaries

As for the information of subsidiaries, the relevant subsidiary reports to the administration headquarters consulting with related department, and make timely disclosure after the approval of the Board of Directors if needed.

3. Monitoring of timely disclosure

Auditors undergo monitoring and verification about the operation systems for properly and timely disclosure of corporate information according to “Audit of cooperate structure for corporate information disclosure” prescribed in “Internal auditing standards”.

4. Effort to the prevention of insider trading

While 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 insider trading.

Our company has internal rules which prescribe even if any director or employee gets the information of the important incidents of the company or any other company, they must not disclose it until the facts become public.

The in-house stock administrator makes sure whether it is not insider trading prior to buying or selling of our company stock by a director or employee.(If it is applicable, the trading is restricted until the measurable facts become public.)

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 prepare the in-house education system including seminars by external instructors.

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