sangetsu

sangetsu

forBusiness

Internal System for the Timely Disclosure of Corporate Information

Disclosure Policy

We abide by the stipulations of the relevant laws and regulations, such as the Securities and Exchange Law, as well as the rules stipulated by stock exchanges. Our policy regarding the disclosure of important information about our corporation, as well as the methods implemented for such disclosures, is established in our internal regulation, the “Standard on Disclosure of Information.”

Internal handling of corporate information is conducted in accordance with the aforementioned standard, while abiding strictly with the Securities and Exchange Law, as well as regulations stipulated by stock exchanges for the disclosure of important information relating to the financial, social, and environmental aspects of our corporation in a fair, timely, and appropriate manner.

System for Reporting Important Information

We classify important information into the following categories:

  • Important facts as defined by the Commercial Law
  • Important facts as defined by the Securities and Exchange Law
  • Important facts as defined by the regulations of stock exchanges
  • Other important facts as determined by persons in charge of information management

Persons who have acquired important information falling into these categories must report to the persons in charge of information management without delay, as stipulated by our internal regulations, the “Insider Trading Control Regulations.” The persons in charge of information management must make a decision on whether or not disclosure of such information is warranted, based on the details of the received reports. Our system is such that once disclosure of such information is deemed necessary, it is then reported to the president and immediately disclosed.

Tasks relating to the disclosure of information are primarily conducted by the Accounting Section of the Administrative Headquarters through the preparation of disclosure documents that comply with the relevant laws and regulations.

Internal Control of Internal Systems Relating to Important Information

We have organized our framework in such a way as to prevent insider trading, which would be in violation of the Securities and Exchange Law, by stipulating not only the “Standard on Disclosure of Information” mentioned above, but also the “Insider Trading Control Regulations.” These rules and regulations stipulate strict abidance with the Securities and Exchange Law, other relevant laws and regulations, as well as the respective stipulations and instructions necessary for the execution of duties. The general manager of Administrative Headquarters, who is a board member, is appointed as the person in charge of managing important information. In the event important information is acquired, such an incident is reported to the managers or equivalent personnel of the main sections. Detailed instructions for handling individual important information is formulated and a manager or an equivalent person of the main section is appointed to take charge of handling such information, as the need arises. The appointed person must manage the assigned important information with the handling method given by the person in charge of the information management.

Internal regulations and standards are available for viewing on the intranet at all times and by all personnel, and personnel are thoroughly informed each time a relevant training seminar or other opportunity arises.

References