CORDY

Disclosure Policy

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Basic policy

The Company respects the concept of Fair Disclosure Rule defined in the Financial Instruments and Exchange Acts. It strives to promote communication and maintain and improve the reliable relationship with stakeholders including shareholders and investors through timely and appropriate disclosure of fair and transparent information and mutual communication. It also strives to improve the corporate management quality and improve corporate value continuously.

Information disclosure standard

The Company manages and discloses with accuracy material corporate information that is required to be disclosed under the Company Act, the Financial Instruments and Exchange Act, Timely Disclosure Rules and other relevant rules. Material information means information that is subject to insider trading regulation, as well as definite and nonpublic financial information that may affect the stock price significantly.
Even when the information is not applicable to the above laws or regulations, the Company proactively and fairly makes available the information that it believes important or useful to its shareholders and investors for better understanding of the Company. It does not disclose personal information, client information and information that will infringe its stakeholders' rights.

Information disclosure method

The Company discloses the information applicable to the Company Act, the Financial Instruments and Exchange Act, Timely Disclosure Rules and other relevant disclosure governance rules via EDINET by the Financial Services Agency and via TDnet by Tokyo Stock Exchange. The Company also discloses such information on our website immediately after the disclosure when necessary.
The Company also discloses information that is not applicable to such rules but that the Company has judged as important or useful for investors, on its website or by other methods.

Prevention of insider trading

The Company has established the Information Security Management Rule and the Prevention of Insider Trading Rule in order to prevent insider trading.
The Company strives to increase understanding and awareness of these rules among board members and employees.

Handling of business results forecasts and future information

Any non-historical fact disclosed in our business results forecasts, future expectation, strategies, targets, etc. are forward-looking statements. Such statements are made on the grounds of a plan, expectation or decision made based on information available at the time and certain assumptions deemed reasonable, while actual business results and other disclosed future information may differ significantly due to various uncertainties including economical situations.

Silent period

In order to prevent the leakage of financial information and to ensure fairness of information disclosure, the Company has adopted a "silent period" that extends from the day following the end of each quarter to the day of business results announcement for that quarter. During this period, the Company does not make any comments nor respond to any questions concerning our business results for the relevant period. During the silent period, however, the Company responds to the questions concerning information that has already been released. If material facts or information including the revision of business results forecasts occurs, the Company discloses the relevant information in a timely manner.

Establishment of internal system

The Company strives to establish and improve the internal system for appropriate information disclosure in compliance with applicable rules, regulations and laws under this Disclosure Policy.