Disclosure Policy

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Overview

Net One Systems Co., Ltd proactively disseminates information about its management strategy, financial position and other corporate information to promote dialogue with shareholders, analysts and other investors in line with Timely Disclosure Rules of the Tokyo Stock Exchange and the principles embodied in the corporate governance rules. In determining whether any particular information is to be made available by Net One as a routine matter or upon request, the company has its Business Committee (chairperson: CEO), whose members include the Director in charge of Disclosure Policy, Corporate Planning Office, Corporate Communications & Investors Relations Officee consider
whether such information falls within the scope of information available to disclose. In doing so, the Company gives due consideration to the timeliness, fairness, accuracy and continuity of disclosure. This disclosure policy aims to develop and maintain realistic investor expectations to enhance management transparency as well as to earn the trust of, and receive a proper evaluation from analysts, shareholder and other investors.

Disclosure Policy

The nature of the information that the company receives and prepares requires it to go through the Business
Committee deliberation via Business Planning Office to determine the level of disclosure under laws, Tokyo Stocks Exchange guideline and our guidelines. Such information may include financial statements, business prospects and adverse impacts on to our business among others. When the Business Committee final decision to disclose any information is made, Board of Director must approve the disclosure before the information is actually disclosed by PR and IR offices.

Information Disclosure Methods

For “important information” defined under the Securities Listing Regulations, the Company will disclose it online on the Timely Disclosure Network (TDnet) of Tokyo Stock Exchange and promptly post the information on its IR website. Regarding other information, where the Company deems it to be useful in fostering an understanding of the Company, the Company actively discloses information through the publication of an annual report and other published IR materials as well as through the distribution of press releases and postings on its IR website.

Quiet Period

The Company has stipulated a quiet period beginning from the next day following the end of a fiscal quarter through
to the announcement of operating results for that quarter to prevent the leakage of earnings information and thus
ensure fairness. During this quiet period, the Company will refrain from answering questions or making other
comments pertaining to its upcoming earnings results and initiating meetings (in person or by phone) with
investment analysts, shareholders, potential investors and the media on items significant to investors, other than
responding to unsolicited inquiries concerning factual information. The quiet period does not, however, prohibit the
Company from disclosing any significant change in earnings expectations under the Exchange’s Timely Disclosure Rules.