Disclosure Policy

VALQUA has established its Disclosure Policy described below. VALQUA makes efforts to infiltrate the policy into the entire group and to provide the stockholders and investors with accurate information in a fair and timely manner.

1. Criteria of disclosure

When disclosing information, VALQUA complies with Securities Exchange Law and “Rules on Timely Disclosure of Company Information by Issuers of Listed Securities” (referred to as “Disclosure Rules”) laid down by Tokyo Stock Exchange. VALQUA may disclose such information that is not defined by the Disclosure Rules as information to be timely disclosed, provided that VALQUA deems that the information should be disclosed. Disclosure of the information is made in a fair manner on the Web site or by any other suitable means.

2. Method of disclosure

When disclosing information to which the Disclosure Rules apply, VALQUA publishes such information on the Timely Disclosure network (TDnet) provided by Tokyo Stock Exchange, in compliance with the provisions of the Disclosure Rules. Although information published on the TDnet is posted also on the VALQUA’s Web site promptly, this can be significantly later than the publication on the TDnet for a reason of the system. It should also be noted that not all information published on the TDnet is posted on the VALQUA’s Web site.

3. Forecast of business results

VALQUA makes efforts to increase the accuracy of forecasting business results and, whenever any change in forecast arises, the change will be promptly disclosed. It should be noted, however, that disclosed information is worked out on the basis of data available at that time, and actual results may differ from the disclosed information, affected by various factors. VALQUA is not liable for any damages that may occur on the basis of disclosed information.

4. Quiet period

Although VALQUA defines the period from the date of quarterly, interim or annual settlement to the date of its announcement as the “quiet period” (self-restraint IR period), VALQUA restrains itself from making comments or response about the content of settlement, results or forecast of business to particular stockholders, investors or the press. However, in case any discrepancies exist between the disclosed forecast of settlement and updated forecast of settlement is found during the mentioned period, VALQUA according to the Disclosure Rules, discloses the information as revised settlement forecast.

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