1．Basic Policy

We will strive to build and maintain a relationship of trust with our shareholders and other stakeholders by disclosing information in a timely, appropriate, fair, and easy-to-understand manner to earn credibility and cultivate a correct understanding about our management and business activities.
In addition to the information in compliance with the Financial Instruments and Exchange Act, the Timely Disclosure Rules adopted by the Tokyo Stock Exchange, and other laws, regulations, rules, etc. (hereafter referred to as “relevant laws, regulations, rules, etc.), we will proactively disclose beneficial corporate information to our shareholders and investors, even if such information is not required to be disclosed, per the purpose of the “Fair Disclosure Rules” stipulated in the Financial Instruments and Exchange Act.

2．Disclosure Method

Information required to disclose under the Timely Disclosure Rules will be released on the Timely Disclosure network provided by the Tokyo Stock Exchange (TDnet), while securities reports and other mandatory reports will be published through the Electronic Disclosure for Investors' NETwork (EDINET) offered by the Financial Services Agency; in either case, the information and reports will also be available on our website.

3．Internal processes for information disclosure

We have streamlined and improved internal structure and procedures to ensure that the information of our Group is promptly consolidated in the Corporate Planning Department, and that information is appropriately disclosed in a prompt, accurate, fair, and easy-to understand manner.

4．Dialogue Policy with our Shareholders and Investors

(1) Information Control, Insider and Silent Period

We have established Basic Rules on Prevention of Insider Trading for all officers, employees and so forth at the PHC Group companies to ensure strict management of insider information. In addition, when engaging in dialogue with investors, the CEO and other members of the management team and those in charge of investor relations take the utmost care in handling insider information and other material information, comply with the Fair Disclosure Rules stipulated in Financial Instruments and Exchange Act, and are committed to engaging in fair dialogue. Specifically, we set a "silent period" from the day after the end of each quarter to the day of the financial results announcement. During this period, we refrain from commenting on or answering questions regarding our financial results, and do not engage in dialogues regarding undisclosed financial outlook. However, if we anticipate a significant change in our financial outlook during the silent period, or if any other circumstances that falls under the criteria for the timely disclosure arise, we will disclose information in accordance with the Timely Disclosure Rules.

(2) Measures for appropriate and effective feedback

Evaluations and opinions acquired through meetings with shareholders, investors, and analysts are compiled on a regular basis and shared with the management team.

(3) Handling of forward-looking information

Among information we disclose, financial outlook and future prospects are based on our assumptions and judgements in light of the limited information available to us at the time of disclosure, and include potential risks and uncertainties. Therefore, please be aware that various factors may cause actual results to differ from these forecasts. Important factors that may affect actual results include, but are not limited to, economic conditions surrounding our business domain, fluctuations in exchange rates, and competitive conditions.