VALQUA, LTD.

IR Policy

VALQUA has established its IR Policy described below. VALQUA makes efforts to infiltrate the policy into the entire group and to provide the stock market participants with accurate information in a fair and timely manner, in addition to working to enhance dialogue.

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. Dialogue with stockholders, etc.

(1) Individual dialogue with stockholders is handled appropriately by the officer in charge of IR or the dedicated IR department within a reasonable scope based on the purpose, etc. thereof.
(2) In addition to individual dialogue with stockholders and investors, VALQUA works to improve bidirectional communication through earnings briefings and external IR events, etc.
(3) The opinions and requests obtained through dialogue with stockholders and investors are used to provide feedback to management and enhance the corporate value of VALQUA.
(4) VALQUA makes efforts to eliminate information disparity between institutional investors by preparing and quickly disclosing English versions of financial summaries and many of the various IR materials.
(5) VALQUA seeks to ensure the control of insider information based on internal regulations, and controls information by defining 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) in which it restrains itself from responding to questions about the content of settlement or forecast of business.

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