Disclosure policy

(1)Standards for information disclosure

In compliance with the “timely disclosure of corporate information of the marketable securities listing regulations set forth by the Financial Instruments and Exchange Act and other legislation as well as the Tokyo Securities Exchange (herein after “timely disclosure rules”), Kamakura Shinsho conducts prompt information disclosure under the fundaments of transparency, fairness, and sustainability. In addition, even if not required by law or timely disclosure rules, we proactively and fairly disclose information deemed beneficial to our shareholders and investors or important for fostering their understanding of our company. We do not disclose personal information, customer information, or information that otherwise infringes on the rights of our shareholders.

(2)Information disclosure methodology

To disclose the information designated by the timely disclosure rules, we make use of the TDnet timely information disclosure system accordingly provided by the Tokyo Securities Exchange. In addition, following disclosure over TDnet, we promptly publish that information on our website as well. We also use our website to publish information deemed important or beneficial even if not required by the timely disclosure rules.

(3)Prevention of insider trading

We prevent insider trading and similar infractions by enacting regulations for managing transactions by insiders. To ensure thorough compliance with insider trading restrictions and promote their understanding and awareness, we also by hold annual seminars for directors and employees, in addition to which we call attention to insider trading through updates and internal notices.

(4)Handling of earnings forecasts and future information

Of the information disclosed by Kamakura Shinsho such as earnings forecasts, future outlooks, strategies, and targets, all items other than those pertaining to historical or present facts constitute forward-looking statements. Such statements are based on information available to the company at the time or plans, expectations, and determinations deemed reasonable at the time. Consequently, actual performance and financial results may differ from our forecasts due to fluctuation in the economic landscape and various other uncertain factors.

(5)Blackout period

To prevent the leakage of earnings results information (including quarterly earnings results) and ensure fair information disclosure, Kamakura Shinsho sets a blackout period of, in principle, the period spanning two weeks preceding the end of the last day of the fiscal period to the date of earnings publication. During this period, the company refrains from answering questions or making comments on earnings results or outlooks. However, in the event that earnings results are expected to vary widely from forecasts, we publish updates in accordance with the timely disclosure rules.

(6)Maintenance of internal systems

Kamakura Shinsho works to maintain and enhance internal systems for implementing proper information disclosure in accordance with relevant legislation and the timely disclosure rules.

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