Disclosure Policy

This document has been translated from the original Japanese document and is provided for reference purposes only. In the event of any discrepancy between this document and the original Japanese document, the original Japanese document shall prevail.

Disclosure Policy

1.Basic Disclosure Policy

 Toyo Construction Co. Ltd. (hereinafter ‘the Company’ or ‘we’) pledges in its Code of Conduct that it discloses its information actively to stakeholders and societies and makes efforts to gain accurate understanding of its business operations.
 We also make efforts to ensure transparency, fairness, continuity and promptness in disclosure of the Company’s information to shareholders and investors (hereinafter ‘the disclosure’). We do make sure the disclosure complies with the Financial Instruments and Exchange Act, the Companies Act and the Securities Listing Regulations of Tokyo Stock Exchange (hereinafter ‘Disclosure-Related Laws and Regulations’). In addition to the above, we actively disclose information that we deem important to our shareholders and investors (hereinafter ‘important information’). We establish disciplines for managing important information and strict operations for it.
 We actively engage in IR activities in believing that evaluations and analyses of the Company based on the disclosure should assist wider and better understanding of the Company and contribute to enhance its medium to long term enterprise value.

2. Method of Disclosure

 The Company discloses important information on the Electronic Disclosure System for Securities Reports and Other Disclosure Documents under the Financial Instruments and Exchange Act (‘EDINET’) operated by Financial Services Agency or the Timely Disclosure Network (‘TDnet’) operated by Tokyo Stock Exchange. Right after the designated filing, we upload subject information on the Company’s website.
 We also actively disclose other important information which is not necessarily a subject to Disclosure-Related Laws and Regulations by posting it on the Company’s website or other ways.

3. Internal Controls for Disclosure

  The Company’s internal rules require the Board of Directors resolution for disclosure of earnings and others subject to Disclosure-Related Laws and Regulations.
  Timely disclosure of the company information is carried out according to ‘Chart of Timely Disclosure Operations’ as an appendix of this policy. The executive officer in charge of the Finance and Accounting Group assumes the responsibility of the Information Handling Person as Tokyo Stock Exchange requires to listed companies. We disclose important decision and earnings information after the resolution of the Board of Directors, and critical occurrences after approval of the CEO concurrently named as a Representative Director and the Chairman without delay.

4. Investor Relation Activities

 In trying to ensure stakeholders better understanding, the Company discloses its key information including financial status and business activities to shareholders and investors in a timely and appropriate manner. In addition, we post important disclosure items on our website and hold financial results briefings for institutional investors and sell side analysts. Materials provided at these briefings are made available on our website.

5. Compliance with Fair Disclosure Rules

 We comply with the Fair Disclosure Rules stipulated in the Financial Instruments and Exchange Act. Except for a case where confidentiality is ensured by a non-disclosure agreement, we do not provide any important and internal information selectively to any institution or person. In case of providing such information, we either put it to the public or ensure non-disclosure obligation of the recipient in advance.

6. Quiet Period

 To prevent leakage of undisclosed earnings information and to ensure fair disclosure, the Company sets its ‘quiet period’ which is one month before quarterly earnings announcement and does not answer any question regarding coming financial results and forecasts during this period. However, this does not apply to matters announced as a timely disclosure.

7. Information on Business Forecasts

  Forward-looking statements such as forecasts, targets, plans, and strategies disclosed by the Company that are not historical facts are based on information available at the time of disclosure and plans, expectations, and judgments based on certain assumptions that the Company deems reasonable and do not constitute a guarantee of the Company’s future performance or development. Actual results may differ significantly due to various risks and uncertain factors.

(appendix)

Chart of Timely Disclosure Operations