Disclosure Policy

We disclose information in compliance with Japanese law (in particular, the Companies Act and the Financial Instruments and Exchange Act) as well as with the timely disclosure rules included in the Tokyo Stock Exchange's Securities Listing Regulations (“Timely Disclosure Rules”). Under the Timely Disclosure Rules, we are required to promptly disclose material information, meaning information that may significantly affect an investment decision (this can include financial/accounting information and emerging developments). Even when there is no such requirement, we may still disclose the information if we think it would prove valuable to investors.

For disclosures required under the Timely Disclosure Rules, we follow the disclosure method stipulated in said rules. That is, after giving the TSE a prior briefing, we will upload the information on Timely Disclosure Network (TDnet), a database operated by Tokyo Stock Exchange. We will then immediately upload the same information to our website. When disclosing non-public information that is not subject to the Timely Disclosure Rules, we try to follow the spirit of the timely disclosure and fair disclosure rules and use appropriate means to make the information available to investors in general, in a manner that is as fair and transparent as possible. If doubt arises as to the fairness of any disclosure we have made to a trading partner under the fair disclosure rule, we will act immediately to resolve the issue.

The head of the Corporate Planning Division (as Chief Information Officer) and head of Finance & Accounting (as the corporate officer in charge of IR) coordinate efforts to collect information from business units and group companies, store the information in the Finance & Accounting Division, and determine whether the information is disclosable. To facilitate communication with investors, the investor relations unit of Finance & Accounting Division’s Enterprise Value Management Department provides investors with information under the supervision of the division's head. Please be aware that dialog with investors is recorded and is shared with the management for the purpose of improving investor relations.

The head of Administration (as Chief Information Officer) and head of Finance & Accounting (as IR Officer) collect information from business units and group companies, store the information in the Finance & Accounting Division, and determine whether the information is disclosable. The Finance & Accounting Division has an investor relations unit that provides investors with information under the supervision of the division's head. Please be aware that dialog with investors is recorded and the analysis of the transcripts is shared with the management for the purpose of improving investor relations.

The contents of this website contain forward-looking statements, such as earnings forecasts, strategies, and goals. These statements are predicated upon assumptions we considered reasonable in light of information available at the time. They are not guarantees of future performance. Actual performance may diverge significantly from what these statements suggested due to a myriad of uncertain variables.

We impose a quiet period in the run-up to an earnings announcement. During this period, we restrict business-related communication with the public in order to prevent selective disclosures of material information that would unfairly benefit some investors over others. However, if, during the quiet period, our performance diverges significantly from what the upcoming announcement would suggest, then we are required under the Timely Disclosure Rules to disclose this information.

In most cases, the Representative Corporate Officer, the corporate officer in charge of IR, or an IR staff member will act as the IR spokesperson to help ensure the accuracy and transparency of our information. However, where warranted, the spokesperson might be a director or Audit Committee member (who may be a company outsider), another type of corporate officer, or an employee.

Our Disclosure Policy covers the following types of disclosures, namely disclosures of non-confidential information accessible to the public and information that is intended to be accessible to the public.

■Disclosures mandated by the TSE
Examples: Corporate decisions and events subject to the TSE rules on timely disclosure, corporate governance reports, registrations of officers as independent officers

■Disclosures mandated under the Financial Instruments and Exchange Act
Examples: Annual securities reports, quarterly financial reports, internal controls reports, irregular reports

■Disclosures mandated under the Companies Act
Examples: Business reporting, unconsolidated and consolidated financial statements and detailed statements attached to such

■Other disclosures
Examples: Summaries of financial results, integrated reports, shareholder newsletters, news releases, information on the company website, other voluntarily disclosures

The Board of Directors has authorized the Disclosure Policy in order to embed meaningful dialogue with shareholders and other investors and thereby support the company’s sustained business growth and building its value over the medium and long term. The board reviews the policy every quarter.
Such dialogue plays a crucial role in helping shareholders and other investors gain a deeper understanding of Kokuyo Group, including its medium-term strategy (as set out, for example, in the medium-term plan), long-term strategy, and long-term vision. It also allows Kokuyo to obtain feedback from the stock market and incorporate the feedback into its business strategies. For this reason, Kokuyo’s president attends shareholder dialogues and briefs the shareholders.
The main channels of dialogue include discussions with institutional investors about our medium- and long-term strategies and other matters, separate as-and-when meetings for the purpose of building or deepening a rapport with the investor in question, quarterly financial results briefings for institutional investors, and company briefings for individual investors.
Our semiannual shareholder newsletter includes an online questionnaire to solicit shareholder feedback and encourage two-way communication.
The corporate officer in charge of IR, along with IR staff, summarize the opinions, requests, and other feedback from shareholders and other investors and report it as and when to the directors and other relevant departments so that the feedback can be incorporated into corporate planning.
We disclose information in compliance with the TSE’s Timely Disclosure Rules. Even in the case of information that we are not required to disclose under the Timely Disclosure Rules, we will still basically disclose the information if we think it would prove valuable to investors. In each case, we will use appropriate channels to disclose the information as proactively and as fairly as possible, in accordance with the rules on fair disclosure set out in the Financial Instruments and Exchange Act.
In our dialogue with shareholders, we safeguard insider information in accordance with the Kokuyo Group Rules on Insider Trading.