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Ticker code : 6197

Basic Policy on Investor Relations

1. Fundamental approach to investor relations

The Company's fundamental approach to investor relations is to consistently disclose accurate information in a timely and fair manner to capital market participants (which include shareholders, investors and analysts, etc.) and other stakeholders of the Company, with such information including The Group's business strategy, business policy, financial data, important management benchmarks and other details useful in assessing corporate value and making investment decisions.

In addition, we engage in active dialogue with capital market participants in order to obtain appropriate market evaluation and strive to reflect comments from the market to the management of the Company.

2. Information disclosure

(1) Standards of information disclosure
We disclose information appropriately (statutory or timely disclosure) on the basis of the Financial Instruments and Exchange Act and related laws and regulations (hereinafter collectively referred to as the "Financial Instruments and Exchange Act") and provisions of the timely disclosure regulations established by the Tokyo Stock Exchange (the "Timely Disclosure Regulations").

We also actively disclose information that we deem as being beneficial to capital market participants, even when disclosure has not been requested, in light of the standards set forth in the Financial Instruments and Exchange Act and the Timely Disclosure Regulations.

(2) Methods of information disclosure
We submit statutory disclosure documents under the Financial Instruments and Exchange Act via the EDINET electronic disclosure network for disclosure of documents such as annual securities reports that companies must disclose in line with the Financial Instruments and Exchange Act. We also disclose information that must be provided in accordance with the Timely Disclosure Regulations via the TDnet timely disclosure network of the Tokyo Stock Exchange, after having furnished prior explanation to the Tokyo Stock exchange when necessary.

We post information to the website of the Company as soon as possible once such information has been disclosed via EDINET or TDnet.

When making information available that is not subject to disclosure under the Financial Instruments and Exchange Act or the Timely Disclosure Regulations, we do so in a manner that is both accurate and fair, by issuing press releases, posting it to the website of the Company, or through other appropriate means.

3. Active promotion of investor relations initiatives

(1) The investor relations framework
Persons in charge of handling information act as officers in charge of investor relations, and divisions overseeing timely discloser act as divisions in charge of investor relations. Meanwhile, corporate planning, finance & accounting, public relations, legal affairs divisions and other related divisions are closely collaborated with the aforementioned in assessing information, preparing materials and disclosing information.

Also, to a reasonable extent, the President & CEO, officers in charge of investor relations, and managers of divisions in charge of investor relations engage in dialogue with capital market participants and others involved in the markets.

(2) Improving communications
We work to improve communications with capital market participants through efforts that include holding financial results presentations, taking part in briefing sessions for retail investors, and responding to day-to-day inquiries.

We also convey details of our business operations, our business strategy, financial data and other such information in a fair and straightforward manner through the website of the Company.

The officers in charge of investor relations supervise such aspects of our communications overall.

4. Handling insider information (important facts that remain undisclosed)

(1) Handling insider information in terms of dialogues and other communications with capital market participants and others
We believe that maintaining equal treatment among capital market participants and others is a fundamental imperative particularly when engaging in dialogue that could involve insider information. On the basis of that notion, we adhere to the Financial Instruments and Exchange Act and otherwise take steps to manage insider information in accordance with our internal Insider Trading Management Regulations which aim to prevent instances of insider trading.

(2) Quiet periods
To ensure that earnings results data is not divulged and that fairness with respect to providing such information is maintained, we observe quiet periods spanning the day subsequent to the balance sheet date of respective quarters and lasting until the announcement of the financial results, during which time we do not comment on financial results or earnings outlooks.

However, we release information as appropriate when a situation calls for disclosure of information (statutory or timely disclosure), in accordance with the Financial Instruments and Exchange Act and the Timely Disclosure Regulations.

We reply to questions and other inquiries regarding previously released information even during the quiet periods.