POLA ORBIS Group Disclosure Policy

Basic Policy

The POLA ORBIS Group strives to actively engage in public relations and investor relations activities and to develop relations of trust with all our shareholders, investors and stakeholders. In order to achieve that, our policy is to disclose information about the Group in a timely and appropriate manner based on the principles of transparency, fairness and consistency, in accordance with the Financial Instrument and Exchange Act and the rules set forth by the relevant financial instrument exchanges regarding timely disclosure. The POLA ORBIS Group also actively discloses any information not covered under these rules if it is deemed to be useful for shareholders or investors.

Method of Disclosing Information

Information covered by the rules regarding timely disclosure set forth by the financial instrument exchange on which the POLA ORBIS Group is listed (information relating to decisions, events, and account settlement,) shall be disclosed via the timely disclosure electronic information system (TDnet:Timely Disclosure network) provided by the exchange after advance explanation is given to the exchange. Following TDnet disclosure, the same information shall be promptly provided to the media and posted on the Company’s website. However, the information’s posting on the Company website may be delayed due to system-related circumstances.

Forecast of Performance and Items Relating to Forecasts for the Future

The POLA ORBIS Group’s  plans, forecasts, strategies and other information that is not based on historical or current facts are plans or forecasts for future performance, which are based on judgments made in light of the information currently available. Therefore, future performance may differ due to fluctuations in a variety of risks and uncertainties as well as changes in the economic situation.

Silent Period

In order to prevent the leakage of financial results information and ensure fairness, the POLA ORBIS Group has established a “Silent Period” that runs from the day immediately following the settlement of financial results (including quarterly results) and the date on which the results are made public. During this period, we will refrain from responding to questions and making comments regarding financial results. However, even during the silent period, we will respond to questions and such regarding information that has already been disclosed.

Compliance with the Disclosure Policy

From the perspective of Corporate Social Responsibility (CSR), the POLA ORBIS Group will keep all the Group’s executives and employees informed of the above disclosure policy and ensure their compliance.