Disclosure Policy

1.Basic Policy on Information Disclosure

ValueCommerce Co., Ltd. (hereinafter “the Company”) will disclose information to its shareholders and other stakeholders in a fair, timely and appropriate manner.


(1) The Company will disclose financial information, management strategies, management issues and non-financial information appropriately in accordance with laws, regulations or the rules of the Tokyo Stock Exchange and will voluntarily seek to provide other information.
The Company will also takes steps to ensure that the disclosed information (particularly non-financial information) is accurate and easy to understand for users and highly usable as information.


(2) When disclosing information, the Company will avoid ambiguous descriptions and will make efforts to ensure that the information will be high value-added statements for users.


(3) The Company will seek to disclose and provide information in English to a reasonable extent.

2.Method of Information Disclosure

(1)Information for statutory disclosure

When disclosing information under the Financial Instruments and Exchange Act, the Company will disclose it by registering with “EDINET,” an electronic disclosure system provided by the Financial Services Agency.
When disclosing information under the Companies Act, the Company will post it on its website.


(2)Information for timely disclosure

When disclosing information based on the rules of the Tokyo Stock Exchange, the Company will disclose it by registering with “TDnet,” a timely disclosure network system provided by the Exchange. The Company will promptly post the disclosed information on its website.


(3)Information for discretionary disclosure

Even if information does not fall under laws, regulations or the rules of the Tokyo Stock Exchange, the Company will post the information on its website if the Company has determined that it is useful for investment decisions.

3.Fair Information Disclosure

The Company will disclose information fairly in accordance with the Fair Disclosure Rules stipulated in the Financial Instruments and Exchange Act.

4.Improvement in Fairness of Information Access

The Company will work to improve the fairness of information access among its shareholders and other stakeholders, and will seek to disclose information utilizing its website.

5.Quiet Period

To secure the fairness of information disclosure, the Company will set a period from the day after the closing date of each quarter to the announcement of financial results for the quarter as a “quiet period.”
During the quiet period, the Company will refrain from giving answers to and making comments on questions about the operating results and the operating forecasts.
However, if an important fact that should be disclosed occurs, the Company will disclose information according to laws, regulations or the rules of the Tokyo Stock Exchange.

6.Forward-looking Statements

Forward-looking statements, including operating forecasts stated in disclosure documents such as summaries of financial results, are based on information available to the Company as of the time of disclosure and certain assumptions which the Company deems reasonable, and the Company does not guarantee their achievement. In addition, actual results, etc. may differ materially from these forward-looking statements due to various factors.

7.Dialogue with Shareholders

(1)The Company will offer opportunities for dialogue with shareholders other than the venue of a shareholders meeting. The Company will strive to listen to shareholders through dialogues, give due attention to their interest and concerns, explain its management policies to them in an easy-to-understand manner, understand the position of its shareholders and other stakeholders in a balanced manner, and respond appropriately based on the understanding.


(2) The Company will consider its response to an application for an individual meeting after taking into consideration the purpose of the meeting, the importance of its content and the attributes of the person the Company will meet, etc.


(3) With regard to the person who will have a dialogue, a director or other executive or the department in charge will respond to a reasonable extent in light of the wishes and major concerns of the shareholder.

8.Company Structure for Information Disclosure

Person responsible for information disclosure Chief financial officer
Department in charge Department in charge of IR
In-house cooperation to assist in dialogues The person responsible for information disclosure will cooperate with related departments so that the necessary information will be consolidated.
Method of dialogue other than individual meetings The Company will enhance the “Investor Relations” on its website and hold an explanatory meeting.
Method of feedback The Company’s management will share the opinions of shareholders received through dialogues as needed and will discuss how to respond to them.
Management of important information under the Financial Instruments and Exchange Act The Company will thoroughly manage important information under the Financial Instruments and Exchange Act in accordance with its internal regulations “Basic Information Security Regulations.”
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