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DISCLOSURE POLICY

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Disclosure Policy

Broadleaf will provide its shareholders and investors with accurate and fair information in a timely manner so that they can get a better understanding of the Company. In addition to disclosure of information that falls under the Companies Act, the Financial Instruments and Exchange Act, other laws and regulations, and the Timely Disclosure Rules specified by the Tokyo Stock Exchange, the Company will actively disclose information that is judged to be useful in making investment decisions even if it does not fall under the Timely Disclosure Rules.

Information Disclosure Method

When disclosing information that falls under the Timely Disclosure Rules, the Company will first disclose it on “TDnet (Timely Disclosure network),” which is a system of the Tokyo Stock Exchange, and then promptly post it on its corporate website.
Information that does not fall under the Timely Disclosure Rules will also be widely disclosed to investors by posting it on its corporate website, etc.

Timely Disclosure Process

Information handling manager or information disclosure administrator will report the information to be disclosed to the Representative Director and President, and then submit it to the Board of Directors for the resolution on the implementation of timely disclosure. If it is urgent and the information handling manager or information disclosure administrator judges that there is no time to carry out the above procedure, he/she can make decisions on timely disclosure without the resolution of the Board of Directors by reporting in advance to the Representative Director and President.

<Diagram of internal system related to timely disclosure of corporate information>

Results Forecasts and Forward-Looking Statements

In addition to the results forecasts, the Company may disclose forward-looking statements such as strategies and plans, etc. Such information is based on the information available at the time of preparation and certain assumptions that are judged to be reasonable. However, actual results may differ significantly from these forecasts due to various risks and uncertainties.

Information Management

During dialogues with investors and shareholders, the Company will pay attention to the handling of insider information and other important information, and comply with the Fair Disclosure Rules specified in the Financial Instruments and Exchange Act. In addition, it will refrain from engaging in dialogue on unannounced results forecasts regardless of the timing of the dialogue or the attribute of the conversation partner.

IR Basic Policy

  • Dialogues (meetings) with the Company’s shareholders or investors will be conducted by Corporate Communication Department under the supervision of the Representative Director and President. Considering the purpose of the dialogue and the attribute of the conversation partner, the Representative Director and President or the Executive Vice President will attend the meeting when necessary.
  • Corporate Communication Department will strive to provide sufficient information to the Company’s shareholders and investors and conduct smooth dialogues by periodically sharing information with related departments. The Department will also strive to understand the shareholder structure in order to promote constructive dialogue.
  • As a means of dialogue other from individual interviews, the Representative Director and President or the Executive Vice President will hold business results briefings for institutional investors.
  • The Representative Director and President or the Executive Vice President will provide feedbacks on the opinions and concerns of shareholders and investors mentioned in the dialogues to the management executives at the Board of Directors or the Management Meeting. The Company will thoroughly manage internal information that corresponds to insider information, in accordance with the Disclosure Policy and the regulation for prevention of insider trading.

Others

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