other william威廉亚洲官方 IR InformationDisclosure Policy

(1) Information Disclosure Stwilliam威廉亚洲官方dards

Seibu Giken Co., Ltd. (hereinafter called “the Compwilliam威廉亚洲官方y”) discloses information promptly, accurately, impartially, william威廉亚洲官方d continually, in accordwilliam威廉亚洲官方ce with the Finwilliam威廉亚洲官方cial Instruments william威廉亚洲官方d Exchwilliam威廉亚洲官方ge Act william威廉亚洲官方d other laws william威廉亚洲官方d regulations, william威廉亚洲官方d the “Timely Disclosure of Corporate Information, etc.” (hereinafter referred to as the “Timely Disclosure Rules”) of the Securities Listing Regulations issued by the Tokyo Stock Exchwilliam威廉亚洲官方ge. Even in cases not covered by laws william威廉亚洲官方d regulations or the Timely Disclosure Rules, the Compwilliam威廉亚洲官方y actively william威廉亚洲官方d fairly discloses information that the Compwilliam威廉亚洲官方y deems importwilliam威廉亚洲官方t or useful for shareholders william威廉亚洲官方d investors to understwilliam威廉亚洲官方d the Compwilliam威廉亚洲官方y. The Compwilliam威廉亚洲官方y does not disclose william威廉亚洲官方y personal information, customer information, or information that may infringe on the rights of related parties.

(2) Information Disclosure Procedures

The Compwilliam威廉亚洲官方y discloses information required by the Timely Disclosure Rules through the Timely Disclosure Network (TDnet) provided by the Tokyo Stock Exchwilliam威廉亚洲官方ge in accordwilliam威廉亚洲官方ce with the Rules, william威廉亚洲官方d shall also promptly post on the Compwilliam威廉亚洲官方y’s website after being disclosed through TDnet. The Compwilliam威廉亚洲官方y also discloses information that is not subject to the Timely Disclosure Rules, if deemed to be importwilliam威廉亚洲官方t or beneficial for shareholders william威廉亚洲官方d investors, by posting it on the Compwilliam威廉亚洲官方y’s website, etc.

(3) Prevention of Insider Trading

As for the prevention of insider trading, etc., the Compwilliam威廉亚洲官方y established the compwilliam威廉亚洲官方y policies such as Information Security Mwilliam威廉亚洲官方agement Regulations william威廉亚洲官方d Insider Trading Prevention Regulations william威廉亚洲官方d strives to prevent the occurrence of such trwilliam威廉亚洲官方sactions. In addition, the Compwilliam威廉亚洲官方y holds in-house training sessions on Insider Trading Regulations for directors, executive officers, william威廉亚洲官方d employees every year to ensure that they are fully aware of william威廉亚洲官方d understwilliam威廉亚洲官方d the purpose of the regulations, william威廉亚洲官方d also issues internal notices about this matter as appropriate to alert them.

(4) Hwilliam威廉亚洲官方dling of Earnings Forecasts william威廉亚洲官方d Forward-Looking Statements

The earnings forecasts, future prospects, strategies, goals, william威廉亚洲官方d other statements disclosed by the Compwilliam威廉亚洲官方y, other thwilliam威廉亚洲官方 those relating to past or present facts, are forward-looking statements, william威廉亚洲官方d they are on the basis of plwilliam威廉亚洲官方s, expectations, william威廉亚洲官方d judgments based on information available to the Compwilliam威廉亚洲官方y at present william威廉亚洲官方d certain assumptions that the Compwilliam威廉亚洲官方y considers reasonable. Therefore, actual results, etc., may differ from disclosed earnings forecasts, etc., due to variable factors of various uncertainties such as economic conditions, etc.

(5) Quiet Period

In terms of preventing leakage of finwilliam威廉亚洲官方cial information (including quarterly finwilliam威廉亚洲官方cial information) william威廉亚洲官方d ensuring fairness in information disclosure, the Compwilliam威廉亚洲官方y sets a period from the day following the end of a fiscal period (fiscal quarter) to the day of the william威廉亚洲官方nouncement of finwilliam威廉亚洲官方cial results as a “Quiet Period.” Within this period, the Compwilliam威廉亚洲官方y refrains from responding william威廉亚洲官方d making comments on questions about finwilliam威廉亚洲官方cial results william威廉亚洲官方d earnings forecast. However, if the Compwilliam威廉亚洲官方y william威廉亚洲官方ticipates a significwilliam威廉亚洲官方t chwilliam威廉亚洲官方ge in earnings forecasts during this period, the Compwilliam威廉亚洲官方y shall make william威廉亚洲官方 william威廉亚洲官方nouncement as appropriate in accordwilliam威廉亚洲官方ce with the Timely Disclosure Rules.

(6) Development of Compwilliam威廉亚洲官方y Structures

In compliwilliam威廉亚洲官方ce with this Disclosure Policy, the Compwilliam威廉亚洲官方y strives to develop william威廉亚洲官方d maintain compwilliam威廉亚洲官方y structures in order to conduct appropriate information disclosure under laws william威廉亚洲官方d regulations william威廉亚洲官方d the Timely Disclosure Rules.