The purpose of these Regulations is to establish a policy for the timely, appropriate and fair disclosure of important corporate information regarding Oizumi Corporation (hereinafter, the “Company”) to comply with laws and regulations related to securities transactions and the rules and regulations of the stock exchanges, as well as to further the understanding of all stakeholders including investors, shareholders and other stakeholders of the Company, and to assist them in forming an appropriate assessment of the Company’s value.

Corporate information shall refer to the following information.

1. Information subject to mandatory disclosure
   Information required to be disclosed by laws and regulations related to securities transactions and the rules and regulations of the stock exchanges on which the Company’s shares are listed.
2. Voluntarily disclosed information
   Information that does not fall under the category of information disclosed under laws and regulations, but that the Disclosure Conference, as stipulated in Article 4, has decided to disclose in order to achieve the purposes of these Regulations.

1. The Company shall establish a Disclosure Office (all executives of the Management Department) to be headed by an Information Management Officer (Managing Officer in charge of information disclosure) appointed by the Board of Directors.

2. Corporate information is reported to the Disclosure Office by the head of each department (internal information manager) in a timely manner, and is managed centrally by the Disclosure Office.

1. The Disclosure Conference shall be established as a body to deliberate whether or not corporate information reported to the Disclosure Office falls under the category of material facts to be disclosed (as stated in the “Handbook for Timely Disclosure by the General Manager of the Competent Department”) and whether or not voluntary disclosure is required.

2. This Conference shall be comprised of members of the Disclosure Office, as well as those deemed necessary by the Information Management Officer.

3. This Conference shall be convened and held when deemed necessary by the Information Management Officer.

The Disclosure Conference shall be primarily tasked with the following responsibilities to ensure that disclosure of corporate information is made in accordance with the purposes of these Regulations.

1. The Conference shall determine if information subject to mandatory disclosure under Article 2 (1) is warranted.
2. The Conference shall determine voluntarily disclosed information as set forth in Article 2 (2).
3. The Conference shall ensure that the contents of these Regulations are thoroughly familiarized within the Company, take appropriate measures to ensure compliance with these Regulations, and provide advice and recommendations to the Company’s divisions as necessary with respect to the purposes of these Regulations.
4. In the event of a violation of these Regulations, the Conference shall provide guidance and recommendations to the officers and employees who have engaged in said violations.
5. In the event that the disclosure of corporate information by the Company is in violation of laws, regulations, or rules, the Conference shall cooperate fully with all investigations by the relevant authorities, and shall instruct the Company’s officers and employees to cooperate fully with said investigations.

1. The department heads (internal information manager) must report to the Disclosure Office any corporate information obtained in the course of their work.

2. The Disclosure Office may request additional information from the respective department heads as necessary.

The Company shall disclose information subject to mandatory disclosure as stipulated in Article 2 (1) and voluntarily disclosed information as stipulated in Article 2 (2), which shall be classified as follows:

1. Occurrences
   The Information Management Officer shall promptly disclose information subject to mandatory disclosure upon becoming aware of the occurrence of such information, or through the Disclosure Conference if voluntarily disclosed information has arisen. However, in cases of emergency, the Information Management Officer shall decide on the disclosure of such information after obtaining the consent of the Company President.
2. Determinations
   When the Board of Directors determines that information subject to mandatory disclosure or voluntarily disclosed information should be disclosed, the Information Management Officer shall promptly implement such disclosure through the Disclosure Conference.
3. Information Related to Financial Results
   Matters related to quarterly and year-end financial results and matters affecting the financial results shall be promptly disclosed by the Information Management Officer upon approval by the Board of Directors. In addition, in the cases of urgent disclosure of information on financial results, such as earnings revisions, the Information Management Officer shall determine the timing and method of disclosure after obtaining the consent of the Company President, without a resolution of the Board of Directors.

1. The Company shall, in principle, disclose information subject to mandatory disclosure as stipulated in Article 2 (1) on the TDnet (Timely Disclosure Network) operated by the Tokyo Stock Exchange in accordance with the “Rules on Timely Disclosure of Corporate Information by Issuers of Listed Securities, etc.” stipulated by the Exchange, and then announce such information to the press without delay and follow the disclosure procedures stipulated by other laws, regulations, and rules.

2. The Company shall disclose voluntarily disclosed information as stipulated in Article 2 (2) in a manner determined by the Disclosure Conference.

3. In the event that corporate information is released to the press in accordance with the provisions of Paragraphs 1 and 2 of this Article, the managing officer in charge of information disclosure or an individual designated by that officer shall make the announcement.

4. In the event of disclosure under the preceding paragraph, the Company shall post the press release on its website without delay.

1. We do not disclose corporate information only to specific third parties. However, this does not apply to voluntarily disclosed information for which the Disclosure Conference determines that disclosure to specific third parties is not inconsistent with the purposes of these Regulations.

2. With the exception of the preceding paragraph, if undisclosed corporate information of the Company is disclosed only to specified third parties, the Company shall promptly disclose such corporate information through the determination of the Disclosure Conference or the Board of Directors.

1. Notwithstanding the provisions of the first paragraph of the preceding article, the head of each department (internal information manager) may provide corporate information to the following parties:

1. Government and public offices that supervise the Company;
2. Attorneys and certified public accountants retained by the Company;
3. Other persons deemed necessary by the Disclosure Conference.

2. Except as provided in Articles 8 and 9 and the preceding paragraph, no officer or employee of the Company shall disseminate undisclosed corporate information outside the Company.

1. When the Company discloses a forecast of business results, it shall clearly state that it was prepared based on assumptions that could be expected at the time of disclosure and that actual business results may differ from the forecasted value.

2. If the Disclosure Conference or the Board of Directors determines that such disclosure will contribute to the purposes of these Regulations, the Company may disclose future information to the extent that such disclosure does not violate laws, regulations, and these Regulations. When disclosing future information, the Company shall clearly indicate that such information is future information.

It is the Company’s basic policy not to comment on rumors, etc. that may influence investment decisions regarding the Company’s stock, etc. However, if the Company receives an inquiry concerning such rumors, etc. in accordance with the rules and regulations of the stock exchanges on which its shares are listed, or if the Disclosure Conference deems it necessary, the Company shall respond to such rumors, etc. in accordance with the decisions of the Conference.

It is the Company’s basic policy not to comment on information contained in analysts’ reports regarding the Company. However, if the Disclosure Conference finds that the information clearly differs from information already disclosed by the Company and that it is not appropriate to leave such information unchallenged, the Company will take appropriate action.

In order to prevent the leakage of information related to financial results and ensure the fairness of information disclosure, the Company’s basic policy is not to make any external comments or respond to inquiries regarding financial results for the relevant quarter during the period from the end of the quarter to the date of announcement of financial results for the relevant quarter in the form of a silent period. However, corporate information that may affect financial results shall be disclosed appropriately in accordance with the “Securities Listing Regulations.”

Matters decided at the Disclosure Conference that are deemed important by the Information Management Officer shall be reported to the Board of Directors.

Revisions or abolishment of these Regulations shall be proposed by the Director of the Management Department and decided by the Board of Directors.