Disclosure Policy

Basic Policy on Information Disclosure

ValueCommerce discloses material information when making any decision or when any event or financial results information arise that may influence investment decisions. Disclosure is made in accordance with the Financial Instruments and Exchange Act, other laws and ordinances and the Tokyo Stock Exchange’s Rules on Timely Disclosure of Corporate Information by Issuer of Listed Security and the Like (hereinafter “the Timely Disclosure Rules”).
ValueCommerce has a basic policy of disclosing information that is not subject to the Timely Disclosure Rules and other regulations in a more impartial, swift, and extensive manner in order to answer the requests of investors and securities analysts.

Information Disclosure Method

Disclosure of material information subject to the Timely Disclosure Rules will be registered on the TDnet System provided by the Tokyo Stock Exchange in accordance with the same Rules.
After the registration, the same materials will be published on ValueCommerce’s website.
When disclosing information that is not subject to the Timely Disclosure Rules, ValueCommerce takes care to maximize impartiality in communication of the information through the website and other media.

Silent Period

In order to prevent the leakage of financial information and to ensure fairness, the company has adopted a “silent period” that commences on the day following the closing date of the each quarterly settlement and ends on the day the related financial statements are released. During this period, the company refrains from responding to any questions concerning its business results or forecasts for the relevant period. However, if there is a significant event that requires disclosure, we will provide appropriate disclosure in accordance with the regulations in a timely manner.

Information Subject to Voluntary Disclosure

ValueCommerce will actively disclose information that is not subject to the Timely Disclosure Rules and that is deemed to help investors with investment decisions. Disclosed information specifically includes supplementary and presentation materials for earnings results briefings. ValueCommerce will work to publish materials on financial results in English and will actively disclose information that helps overseas investors to make investment decisions.

Internal Information Control

ValueCommerce has instituted regulations on the prevention of insider trading for the objectives of promoting timely disclosure of material internal information and of ensuring social confidence in it. To make the regulations fully known, ValueCommerce offers education on insider trading to all its officers and employees.

Treatment of Earnings Outlook and Relevant Materials

ValueCommerce may offer information about its future outlook in the summary of financial results and other disclosure materials. Briefing and other materials and Q&A sessions may include forward-looking information and statements. In any case, they are based on ValueCommerce’s judgments made under certain assumptions at the time of preparation. The forward-looking information and statements may therefore be subject to change without prior notice following changes in the assumptions and actual earnings results may differ materially from the forward-looking information and statements due to various factors.

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