Disclosure Policies

(1) Criteria for Information Disclosure

KBK discloses corporate information promptly, based on the qualities of transparency, fairness and continuity, in accordance with the Financial Instruments and Exchange Act and other laws and regulations as well as “Timely Disclosure of Corporate Information, etc.” in the Securities Listing Regulations issued by the Tokyo Stock Exchange (hereinafter the “Timely Disclosure Regulations”). Even in cases not subject to the provisions of law, regulation or the Timely Disclosure Regulations, we engage in the proactive and fair disclosure of information deemed beneficial to shareholders or investors, or useful in understanding KBK. We do not disclose personal information, customer information, or information that would violate the rights of those involved.

(2) Method of Information Disclosure

KBK discloses information under the Timely Disclosure Regulations using the timely disclosure network (TDnet) provided by the Tokyo Stock Exchange under the Timely Disclosure Regulations. In addition, after information has been disclosed through TDnet, it is also promptly displayed on KBK’s homepage. Even in cases not subject to the Timely Disclosure Regulations, we disclose information deemed beneficial to shareholders or investors, or useful in understanding KBK, on the homepage.

(3) Measures to Prevent Insider Trading

KBK aims to prevent insider trading through the establishment of Information Management Regulations and Insider Trading Management Regulations. In addition, we are also working to disseminate knowledge and promote understanding and awareness of insider trading restrictions through measures such as conducting an annual workshop for officers and employees, and distributing handbooks. We also call attention to insider trading restrictions through internal notifications, as appropriate.

(4) The Treatment of Results Forecasts and Forward-looking Information

All of the results forecasts, future outlooks, strategies, targets, etc. disclosed by KBK, except for those concerning past or current facts, describe our outlook for the future, which are supported by our plans, expectations and judgements based on information available at the time, and certain assumptions deemed reasonable. Actual results may differ therefore from the results forecasts previously disclosed, due to variations in a range of uncertain factors such as the economic climate.

(5) Quiet Period

From the dual perspectives of preventing leakage of KBK’s financial results (including quarterly financial results) and ensuring fair disclosure of information, we have established a quiet period from the day following the final day of the fiscal year (or fiscal quarter) until the day when the relevant financial results are announced. During each quiet period, we will refrain from commenting or answering questions related to results forecasts or financial outlook. However, where the results forecast is expected to change significantly during the quiet period, we will make a public announcement as appropriate, in accordance with the Timely Disclosure Regulations.

(6) Establishment of Internal Frameworks

Based on these disclosure policies, we will establish and enhance KBK’s internal frameworks to ensure appropriate disclosure of information, in accordance with current laws and regulations as well as the Timely Disclosure Regulations.