Disclosure policy

1. Basic policy

We aim to maximize enterprise value on a medium- to long-term basis and to become the most trusted company in the Auto-ID solutions industry worldwide through constructive dialogue with stakeholders. To that end, we shall endeavor to disclose information with consistency, continuity, speed, fairness and transparency.

2. Criteria for disclosure

We shall disclose information in compliance with applicable laws and regulations including the Companies Act, the Financial Instruments and Exchange Act and the Tokyo Stock Exchange (TSE)’s Timely Disclosure Rules for listed companies. We shall also proactively disclose other financial and non-financial information that help deepen stakeholders’ understanding of the company.

3. Methods of disclosure

We shall provide information required by applicable laws and regulations via stipulated means, for example, submitting information in accordance with the TSE’s Timely Disclosure Rules to its Timely Disclosure network (TDnet) while promptly publishing the same on our corporate website. Other information such as press releases and presentation materials with summary notes used at financial results briefings for institutional investors and analysts shall also be communicated through our website or other channels easily accessible by our stakeholders.
When disclosing information in Japanese, we shall make every effort to ensure fairness to all stakeholders by providing English translations at the same time or at the earliest time possible.

4. Quiet period

We shall observe a quiet period for fiscal quarters/years starting on the day after the close of the quarter/year through to the company’s financial results announcement for the corresponding quarter/year to prevent information leaks and ensure fairness. During this period, we shall neither answer questions nor comment on earnings and earnings forecasts that have not been made public.
Exceptions are i) information on the company’s business model, ESG initiatives and other aspects of our medium- to long-term strategies that are not related to our immediate financial results or business progresses, and ii) information on material events that must be disclosed in accordance with the TSE’s Timely Disclosure Rules should such events occur during the quiet period.

5. Forward-looking information

The information we provide includes forward-looking statements such as earnings forecasts and performance projections from our medium-term management plan, which are judgements based on information available to the company at the time of disclosure. Actual results may differ materially due to various factors including changes in global economic conditions, business environments or foreign exchange rates.

6. Response to third-party communications

We shall comply with the Fair Disclosure Rules (introduced in 2017 as a partial amendment to the Financial Instruments and Exchange Act) to make public disclosure of material non-public information should such information be disclosed intentionally or unintentionally to a third party specified by the aforementioned rules. Policy and procedure in case material non-public information being disclosed to third parties are as shown in the diagram below. Also, we shall not mention or endorse comments, evaluations and earnings forecasts concerning the company in analyst reports or other third-party sources.

Policy and procedure in case material non-public information being disclosed to third parties

1. 1.
   Person disclosing material non-public information notifies IR Dept.
2. 2.
   IR Dept. reports to the Corporate Communications Officer (CCO) with an announcement draft, which is subsequently reported to the Chairman of Risk Management Committee.
3. 3.
   The Chairman of Risk Management Committee reports to the CEO following confirmation.
4. 4.
   CEO instructs PR Dept. to post the information on the company’s website following final confirmation.
5. 5.
   PR Dept. posts the information on the website and makes internal notification.
6. 6.
   In case website post is not possible, IR Dept. requests General Affairs Dept. to conduct timely disclosure procedures.