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DISCLOSURE POLICY

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Disclosure Policy

Broadleaf provides shareholders and investors with accurate and fair information in a timely manner for better understanding of the Company. In addition to disclosure of information that complies with the Financial Instruments and Exchange Act and the Timely Disclosure Rules established by the Tokyo Stock Exchange, the Company proactively discloses information that may be useful for better understanding of the Company.

Information Disclosure Method

When disclosing information which corresponds to the Timely Disclosure Rules, the Company will post the information on corporate website promptly after posting it on the Tokyo Stock Exchange website through TDnet.
Information which does not correspond to the Timely Disclosure Rules will also be distributed to investors and disclosed on corporate IR website so that the information is provided accurately and fairly to investors.

Timely Disclosure Process

Information handling manager or information disclosure manager shall report the content of the disclosure to the President and Representative Director, discuss the content in the Board of Directors, and make decision on the implementation of timely disclosure. If it is urgent and it is judged that there is not enough time to carry out the above procedure, information handling manager or information disclosure manager shall report to the President and Representative Director, and without discussing in the Board of Directors, they can make decision on the preceding paragraph.

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

Result Forecast

In addition to the result forecast submitted to the Tokyo Stock Exchange where the Company’s stocks are listed, the Company may provide information regarding the result forecast using other methods. IR releases, Q & A sessions at financial results briefings and analyst meetings, etc. may also include information on plans, forecasts, strategies, etc. This information is judged to be reasonable by the Company based on the information available at the time of preparation but contains risks and uncertainties. Please note that actual business results may differ significantly from these forecasts due to various factors.

Disclosure of information to third parties and result forecasts from third parties

The Company only mentions information that has already been made public or known, or information about the general business environment at individual meetings with institutional investors and analysts. The Company do not support any comments or forecasts regarding the Company by any third party.

Silence period

The Company sets a silence period from the day after the end of the quarter to the date of announcement of financial results for the purpose of preventing leakage of financial results (including quarterly financial results) and ensure fairness. During this period, the Company refrains from answering questions or commenting on the financial results and result forecasts. However, if business results are expected to significantly deviate from the result forecasts during this silence period, the Company will make an appropriate announcement in accordance with the disclosure rules and corporate information disclosure criteria.

(Reference: Period for refraining from IR activities)
 1st quarter: from April 1st to announcement date of the financial results of the 1st Quarter
 2nd quarter: from July 1st to announcement date of the financial results of the 2nd Quarter
 3rd quarter: from October 1st to announcement date of the financial results of the 3rd Quarter
 Full year: from January 1st to announcement date of the financial results of the fiscal year

IR Basic Policy

  • Dialogues (interviews) between shareholders or investors will be conducted by Investor Relations Department under the supervision of the President and CEO. Taking the purpose of the dialogue and the attribute of the interviewer into account, the President and CEO will attend the meeting when needed.
  • Investor Relations Department will endeavor to provide sufficient information to 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 President and CEO holds business results briefings for institutional investors.
  • The President and CEO will provide feedback 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.

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