TOTETSU KOGYO CO.,LTD.

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Disclosure Policy

1. Basic policies concerning the disclosure of information

When important information regarding Totetsu Kogyo (hereinafter referred to as the “Company”) (such as confirmed facts, details of events, and information pertaining to the settlement of accounts) that has an impact on investment decisions arises, such information shall be disclosed by the Company pursuant to relevant laws and regulations, as well as the Timely Disclosure Rules as set forth by the Tokyo Stock Exchange. In addition, we will endeavour to proactively disclose, on a fair and prompt basis, information that, despite not being subject to the Timely Disclosure Rules, has been determined to be useful to shareholders and investors.

2. Methods by which information is disclosed

Pursuant to the Timely Disclosure Rules, important information that is subject thereto shall be provided upon being registered with the timely disclosure network (TDnet) operated by the Tokyo Stock Exchange; the same materials shall also be promptly posted to the Company’s website. Even where information not subject to the Timely Disclosure Rules is disclosed, we will see to it that such information is transmitted through our website or other media channels as accurately and fairly as possible in accordance with the aim of timely disclosure.

3. Handling of undisclosed information

Except in situations in which the confidentiality of information is guaranteed by a specific non-disclosure agreement, etc., the Company will not selectively disclose undisclosed important company information to parties involved in the transactions such as shareholders, institutional investors, securities analysts and individual investors. In the situation that undisclosed important company information is selectively disclosed unintentionally, the Company will promptly disclose such information in principle.

4. Future projections

In addition to providing earnings forecasts as stated in our brief announcement of financial results, we also release information relating to medium-term management plans and other future projections. Such information is based on information available at the time in question and on certain assumptions deemed by the Company to be reasonable, such that actual results may differ from such plans and predictions according to various factors. Moreover, please note that such future information, plans, and projections are also subject to revision according to changes in circumstances and assumptions.

5. Quiet period

In order to prevent leaks of settlement information and ensure fairness, the period extending from the day following the settlement date to the day on which earnings results are reported shall constitute a quiet period during which we shall refrain from making comments and responding to questions regarding the settlement of accounts. Provided, however, that when the possibility arises that an earnings forecast will be significantly altered during a quiet period, such possibility shall be disclosed pursuant to the Timely Disclosure Rules.

6. Internal company structure pertaining to the disclosure of information

Based on this disclosure policy, the Company has created a structure to appropriately disclose information in a timely manner.

 
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