DAIKEN

Disclosure Policy

Overview of Timely Disclosure

1. Policy

The Company has established the Group Code of Conduct with respect to the disclosure of corporate information, and we have declared that we will communicate not only with shareholders but also with society as a whole and disclose corporate information in an active and fair manner in order to increase the transparency of corporate activities. Additionally, we have communicated this commitment throughout the organization to ensure the full awareness and commitment of all employees.

2. Information Disclosure System

With regard to the information that must be disclosed under the Financial Instruments and Exchange Act and other applicable laws and regulations, our information disclosure system is designed so that when the Board of Directors of the Company resolve or decide to disclose information or when the Company recognizes the need for such disclosure, the information shall be disclosed immediately.

In order to promptly and appropriately handle the risks that have already occurred, the Company has established the Risk Management Rules and the Crisis Response Manual, among other policies and regulations, to ensure that information on important matters is immediately communicated by each department and subsidiary to the Corporate Information Handling Officer.

With regard to important information, the necessity and details of information disclosure are studied by the responsible committees, such as the Risk and Compliance Management Committee, as well as by the relevant departments, such as the Accounting Department and the Corporate Planning Department, and then the information is disclosed and made public under the instructions of the Corporate Information Handling Officer.

The Company’s policy for the management of corporate information is set forth in the Information Management Rules, Rules regarding Insider Trading Regulations, and other documents to ensure the maintenance of confidentiality of important internal information and the prevention of insider trading.

3. Monitoring of Timely Disclosure System

In order for the Company to continue to maintain and improve the timeliness of information disclosure, the Audit and Supervisory Committee and Internal Audit Department supervise the execution of the Company’s business operations from an independent standpoint to ensure that the Timely Disclosure System is established and effectively operated and that the business operations are conducted lawfully.