Verschwiegenheitsrichtlinie

1. Basic Policy

Recognizing that getting support and trust with respect to our corporate activities from all stakeholders including shareholders as well as contributing to formation of a fair capital market as a listed company is one of the highest management priorities, Sumida Corporation (hereinafter referred to as “Sumida”) proactively discloses information stipulated by applicable laws and regulations and rules of a stock exchange in a timely and fair manner.

2. Information to Be Disclosed

Sumida discloses the following information.

(1) Mandatory disclosure

Information required to disclose by the Company Act and the Financial Instruments and Exchange Act, etc.

(2) Timely disclosure

Information required to disclose by the timely disclosure rules of the Tokyo Stock Exchange.

(3) Voluntary disclosure

Information that could affect investment decisions by shareholders and investors, though not falling under information described above (1) and (2).

(4) Other disclosure

Information that could supplement information described above (1) ,(2) and (3) or help investment decisions by shareholders and investors.

In addition to the above-described information, Sumida provides information deemed to be useful for shareholders and investors to better understand Sumida, through Website, Sumida Report and IR meetings held for institutional and individual investors

3. Material Undisclosed Information

If an information reported in the media proves to be material undisclosed information, Sumida will immediately disclose it via appropriate methods in a prompt manner. 

4. Information Disclosure Methods

Sumida discloses information through such methods as stipulated by applicable laws and regulations or rules of a stock exchange. It also posts such publicly disclosed information on its Website. 

5. Quiet Period

To prevent the leakage of business results and future forecast that could affect share prices on the stock market as well as to ensure fairness, Sumida refrains from making any comments on its business results and responding to any inquiries thereof during the preparation period for financial statements reporting. 

6. Information Disclosure Structure

In terms of disclosure of Material Facts at Sumida, Corporate Office and Accounting Department respectively collect comprehensive information on corporate decisions/occurrence of material fact and financial results from the related departments and prepares the documents that contains adequate information helpful for investment decisions while observing applicable laws and regulations as well as rules of a stock exchange. The documents, after confirmed by all members of the board of directors in advance, will be disclosed at an appropriate time with the careful attention to fairness of investors. Public relation/IR team serves as a point of contact with the Tokyo Stock Exchange in terms of information disclosure and handles external communications. 

7. Constructive Communications

Sumida makes efforts to have a sincere dialogue with our shareholders and investors through its IR activities. To make the dialogue more constructive, requests and opinions received from such communications are appropriately shared with our management and related departments. 

8. Measures to Prevent Insider Trading

Sumida has established basic internal rules for the appropriate management of inside information and the proper way of trading of Sumida shares. To prevent insider trading, Sumida promotes a thorough understanding and awareness of these rules by officers and employees and uses monitoring system for an appropriate share trading by them. In addition, a training workshop is held as needed by inviting a lawyer specialized in insider trading as a lecturer.

9. Forward Looking Statements

Disclosure information contains certain “forward-looking statements” about Sumida’s plans, strategies and performance. Such statements made with the information available at the time of disclosure and certain assumptions are subject to various factors such as subsequent changes in market environment and business lineup that could cause actual results to differ materially from those projected or implied in “forward-looking statements”.

Last update: November 20, 2018