Disclosure Policy

Established on July 1, 2020

Basic policy

ShinMaywa Industries, Ltd. (the "Company") complies with laws and regulations and the rules prescribed by the Tokyo Stock Exchange, in accordance with the "Clean, Sincere, Steady, and Enterprising" spirit set forth in its Corporate Principles. It also seeks to embody the requirement declared in its Code of Conduct to "Increase transparency through appropriate information disclosure and acquire stakeholders’ trust." by providing information necessary for investment decision making by shareholders and investors in a fair and appropriate manner.
Furthermore, the Company publishes various types of regulatory information related to the Company through its website in conjunction with submission of such information to the relevant organizations.

1. Information Disclosure Standards

The Company discloses information in accordance with the Companies Act, the Financial Instruments and Exchange Act, and other laws and regulations, as well as rules on the timely disclosure of corporate information stipulated in the "Securities Listing Regulations" of the Tokyo Stock Exchange (the "Timely Disclosure Rules").
At the same time, the Company will proactively disclose information that is deemed to affect investment decisions, even when such information is not subject to the Timely Disclosure Rules.

2.Information Disclosure Methods

Information subject to the Timely Disclosure Rules is promptly published on the Company’s website following the disclosure via the Timely Disclosure Network (TDnet) provided by the Tokyo Stock Exchange.
In addition, to secure the equal treatment of all stakeholders, all disclosed information is published on the Company’s website, even if it is not subject to the Timely Disclosure Rules.

3.Management of Inside Information

The Company endeavors daily to appropriately manage a variety of material information. To prevent insider trading, it determines the personnel who will be involved with the relevant information in the period until disclosure, and it also communicates the information widely within the Company after it has been published.

4.Handling of Earnings Forecasts and Forward-Looking Information

The earnings forecasts, management policies, various strategies, and targets disclosed by the Company, excluding established facts and public information, are all material related to forward-looking information.
Their content is presented on the basis of assumptions, plans and decisions considered to be reasonable at the time of disclosure by the Company. However, actual business performance and progress may vary significantly due to the emergence of unexpected risks, changes in preconditions, and other factors.

5.Quiet Period

To prevent leakage of account settlement information and maintain fairness between all stakeholders, the Company has defined a quiet period from the day after the last day of its accounting periods (including the fourth quarter) until the date of announcement of financial results during which the Company will refrain from responding to or making comments on questions related to the financial results.
However, if it is expected that there will be a divergence from the latest earnings forecast that falls under the Timely Disclosure Rules, prompt and timely disclosure will be made, even during the quiet period.

6.Development of Internal Systems/Structures

The Company has arranged and maintains systems and structures for management in accordance with this Disclosure Policy. It has also established processes for information disclosure departments to follow, from completion of previously specified approval flows to disclosure.