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Information Disclosure Policy

Acrodea implements timely and appropriate information disclosures in accordance with relevant laws such as the Financial Products Trading Law and with rules related to timely disclosure that are established by the Tokyo Stock Exchange, and is committed to equality among all market participants for accessibility to material information that may influence investment decisions.

Method of Information Disclosure

For information subject to timely disclosure rules and material information that influences investment decisions, Acrodea is committed to equality among all market participants for accessibility through a variety of means, including registration to TDnet (information delivery system for timely disclosures) of the Tokyo Stock Exchange, electronic distribution of press releases, publication on the company’s own website, etc. Policy provides that any other information not subject to the timely disclosure rules is nonetheless disclosed rapidly, accurately, and fairly through appropriate methods in line with the paramount objectives of timely disclosure.

Public Relations Information Disclosure

Because the company is a B-to-B business operation and engaged in middleware that does not deliver visually identifiable products, Acrodea intends to release actively general publicity as a policy that fosters a deeper understanding of the company among shareholders and investors. For items not subject to timely disclosure according to the timely disclosure rules set forth by the Tokyo Stock Exchange and with minor impact to business performance, the company nonetheless actively promotes disclosures on TDnet for equal accessibility by market participants.

Quiet Periods

In order to prevent leakage of financial closing information and to ensure fairness, Acrodea institutes quiet periods for approximately three weeks prior to the announcement of any financial results. During this time, the company will decline to reply or comment on inquiries regarding financial results, and will withdraw from holding private meetings or corporate briefings. Any incidents arising during a quiet period that are subject to timely disclosure, however, will be appropriately publicized according to timely disclosure rules. Despite the observance in progress for a quiet period, the company may also address any questions within the scope of information already publicized.