Disclosure Policy

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Fundamental Policy

SEIREN (hereinafter referred to as the Company) has established a disclosure policy which shall require the Company to disclose any important information regarding its management, whether positive or negative, in a voluntary, fair, lawful and appropriate manner by complying with all applicable laws and regulations.   

Internal System for Timely Disclosure

The Company has designated its "General Affairs Division" (hereinafter referred to as the General Affairs Division) as a contact point for disclosure of important information about the Company (herein after referred to as Important Company Information) so that the General Affairs Division, in close coordination with the Company's Corporate Strategy & Planning Division, shall disclosure important Company Information, whether any decision made by the Company or any event that occurred relevant to the Company, so as to make the Important Company Information available to investors. 
 
Any Impotent Company Information to be decided on by the Company regarding its management shall be discussed and decided on at meetings of the Company's Board of Directors (hereinafter referred to as the Board of Directors) according to the Rules of the Board of Directors and any Important Company Information to be decided on by the Company regarding its operations shall be discussed and decided on at meetings of the Company's Management Council (to be convened on a monthly basis attended by the Company's directors, executive officers and heads of related divisions including the General Affairs Division, as well as the Company's auditors) according to the rules set forth by the Company with regard to the Management Council. 
 
Any Important Company Information thus decided on by the Company shall be then discussed between the General Affairs Division and the Corporate Strategy & Planning Division as described above to determine whether to disclose the Important Company Information by reference to the disclosure requirements specified by the Tokyo Stock Exchange and swiftly disclose it if its disclosure is required to be made as  a result of the discussion between the two divisions.
 
It should be noted that the Company has set up a "Insider Trading Control Committee" to make constant checks on trading of the Company's shares by any of its officers and employees in order to prevent insider trading.  Therefore, the Company's Disclosure Policy stipulates that any Important Company Information regarding the Company's shares is to be treated as strictly confidential by all attendees to meetings for discussion on the Important Company Information and all personnel performing clerical work related to disclosure of the Important Company Information before its official announcement.

Information Disclosure Methods

Any Important Company Information required to be disclosed based on the specified Timely Disclosure Rules shall be disclosed using TDnet (Timely Disclosure Network) provided by the Tokyo Stock Exchange, while being posted on the Company's homepage at an appropriate timing.  It should be noted that any Important Company Information, even if not required to be disclosed based on the specified Timely Disclosure Rules, shall be posted on the Company's homepage from time to time in line with the intent of the specified Timely Disclosure Rules.