Basic Policy

In order to ensure transparency of corporate management, TSUKURUBA Inc. (hereinafter “the Company”) will strive to disclose corporate information in timely and suitable manner. With regard to disclosure of such information, the Company will proactively endeavor to expand the scope of disclosure beyond information required by the Financial Instruments and Exchange Act and other laws as well as Timely Disclosure Rules set forth by the Tokyo Stock Exchange and regulations to information deemed beneficial to facilitate understanding of the Company for all stakeholders.

Method of Information Disclosure

The disclosure of information applicable to Timely Disclosure Rules is disclosed via the timely disclosure information communications system (TDnet) provided by the Tokyo Stock Exchange in accordance with said rules. Furthermore, following disclosure the Company immediately publish said information to its IR website. Information not subject to Time Disclosure Rules is also published fairly to that website in the spirit of timely disclosure.

Prevention of insider trading

The Company formulates internal rules to prevent Insider Trading, and shall publicize and enlighten these rules among all the executives and employees. The Company prevents insider trading by appropriate control of material information that could affect investors’ decisions and appropriate information disclosure in accordance with all relevant laws and Timely Disclosure Rules.

Quiet Period

The Company sets the “quiet period” from the day following the settlement day of the accounting period until the announcement of financial results (quarterly, or annual) for the purpose of ensuring fairness and preventing the leakage of earnings-related information. During this period, the Company will refrain from replying to queries concerning operating results or commenting on such matters. However, exceptions may be made when material events affecting investors’ decision arise, or required by laws or Timely Disclosure Rules.

Internal structures

In accordance with this Disclosure Policy, the Company strives to improve and enhance our internal structure in order to provide appropriate information disclosure in accordance with the laws and Timely Disclosure Rules.


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