The basic policy of Yellow Hat Ltd. (hereinafter, the “Company”) on information disclosure is to disclose information in a fair, swift, and accurate manner to all stakeholders, including customers, shareholders, and investors. To achieve this, the Company engages in information disclosure in accordance with the Financial Instruments and Exchange Act and the Timely Disclosure Rules of the Tokyo Stock Exchange. In addition, the Company strives to build relationships of trust with shareholders, investors, and other stakeholders by actively engaging in dialogue with them.
2. Methods of information disclosure
The Company engages in disclosure based on the Financial Instruments and Exchange Act via the Electronic Disclosure for Investors’ Network (EDINET) operated by the Financial Services Agency. The Company engages in disclosure based on the Securities Listing Regulations, etc. of the Tokyo Stock Exchange via the Timely Disclosure Network (TDnet) operated by the Tokyo Stock Exchange. In addition, disclosure information, including the above, is posted on the IR information page of the Company website.
3. Prevention of insider trading
The Company has established internal rules with the aim of managing and handling important information appropriately and preventing insider trading. In addition, the Company raises awareness about insider training via internal notices, etc., striving to promote the thorough dissemination of information and understanding among all Group employees.
4. Financial results forecasts
Financial results forecasts released by the Company are calculated based on judgements and suppositions in accordance with information obtainable as of the date of their announcement. The Company makes no promises or guarantees as to the accuracy or completeness of this information, and actual results may differ from forecasts due to changes in financial markets, economic conditions, the business environment, etc. after their release.
5. Silent periods
In order to prevent the leaking of financial results information and ensure fairness, the Company employs a “silent period” from two weeks before the account closing date until the date of the release of financial results. During this time, the Company refrains from making comments or answering questions concerning financial results details and also refrains from conducting individual meetings and telephone meetings, etc. However, even during silent periods, the Company does engage in information disclosure in accordance with the Timely Disclosure Rules.
6. Constructive dialogue
The Company has established a department in charge of investor relations within the Human Resources and General Affairs Department, and this department engages in investor relation activities. Striving to build relationships of trust, the department actively engages in investor relation activities, such as holding financial results briefings for shareholders and investors twice a year and providing individual meetings, etc.
7. Internal systems maintenance
The Company strives to develop and maintain internal systems in order to appropriately operate its disclosure policy and engage in appropriate information disclosure in accordance with the Timely Disclosure Rules.
The Company thoroughly disseminates information on and observes this disclosure policy and strives for fair disclosure.