Basic Policy

Moriroku Holdings Company, Ltd. (hereinafter referred to as "the Company") will disclose accurate corporate information to all stakeholders, including shareholders and investors, in a timely and fair manner. The Company will also strive to communicate actively with our stakeholders and to ensure that the feedback we receive is appropriately reflected in our corporate activities.

Disclosures subject to this policy

This policy applies to the following disclosures.

Statutory disclosures

• Disclosures in accordance with the Financial Instruments and Exchange Act
  Securities Reports, Semiannual Reports, Internal Control Reports, Extraordinary Reports, etc.
• Disclosures in accordance with the Companies Act
  Business Reports, Financial Statements, Consolidated Financial Statements, etc.

Timely disclosures

• Corporate decisions, facts which occurred, financial information, etc. for which the Tokyo Stock Exchange requires timely disclosure
• Corporate governance reports, notices filed to the TSE regarding appointment of executives, etc.

Other disclosures

• PR information not applicable to timely disclosure
• Disclosure materials related to IR activities
• Other voluntary disclosure materials

Information Disclosure System

The director in charge of Investors Relations is responsible for handling information, and the IR Department is the department in charge of the handling, and work with relevant departments to consolidate information, examine the need for disclosure, and prepare contents for disclosure.

Information that falls under the category of timely disclosure will be disclosed through the Timely Disclosure Network (TDnet) provided by the Tokyo Stock Exchange and will also be promptly posted on the Company's website.

Disclosure System Chart

Spokespersons for IR activities

To ensure the accuracy of information and fairness of disclosure, in principle, directors, executive officers, and persons in charge of investor relations serve as spokespersons for IR activities conducted by the Company. In addition, officers and employees other than those mentioned above may also serve as spokespersons when necessary.

Policy for Constructive Dialogue with Shareholders

The director in charge of IR oversees and works with other members of management to enhance dialogue. In addition to disclosing information as required by law and regulations, the IR Department holds briefings for financial results and medium-term management plan, and discloses information on the company's website to promote understanding of the company's business situation and enhance dialogue. Feedback from dialogue is conveyed to the Board of Directors and operating companies to help with management decisions.

Quiet Period

In order to prevent leakage of financial information, the period between the end of each financial year and the announcement of financial results is designated as a quiet period, during which the Company can make no comments or answer questions on the relevant financial information.

Prevention of Insider Trading

The Company has established internal regulations for the appropriate management of important information relating to the Company and the prevention of insider trading. The Company promotes awareness and understanding of these regulations among all employees.