PRONEXUS' management philosophy defines our mission to society as contributing to the sound growth of client companies and capital markets by promoting proper corporate valuations and investment activities by investors via our support services for corporate disclosure and investor relations activities. We execute prompt, pertinent and fair disclosure activities for our shareholders and investors in accordance with our management philosophy and social as well as environmental codes of conduct based on this philosophy. By continuing this practice, we strive to pursue a higher degree of management transparency and earn the trust of society as a good corporate citizen.
The following disclosure policy has been created in order to make this fundamental policy known both within and outside of the Company and to ensure that PRONEXUS' disclosure practices are always executed according to appropriate standards, methods, and regimes.
- Information Disclosure Standards
We disclose information in accordance with the Companies Act, Financial Instruments and Exchange Act, and other laws, as well as rules on the timely disclosure of company information stipulated in the Tokyo Stock Exchange's Securities Listing Regulations (hereafter "Timely Disclosure Rules"). When information related to determined facts, occurring facts and account settlement related matters that affect significant impact on investment decisions occurs, such information will be promptly disclosed following the standards outlined in the Timely Disclosure Rules. At the same time, we will actively disclose information that is deemed to be important or beneficial in order for investors to understand the Company, even when it is not subject to the Timely Disclosure Rules.
However, personal information, client information and information that may infringe upon the rights of a related party will not be disclosed. - Information Disclosure Methods
Information subject to the Timely Disclosure Rules is promptly published on our corporate website following registration in the Timely Disclosure Network (TDnet) provided by Tokyo Stock Exchange Group, Inc. Information that is not subject to the Timely Disclosure Rules is also openly announced via various media including our corporate website. - Prevention of Insider Trading
We have stipulated internal rules for the appropriate handling of important information and prevention of insider trading, and are working to promote thorough understanding and awareness of these rules by employees across the entire PRONEXUS Group. - Handling of Earnings Forecasts and Future Information
Any non-historic fact disclosed in our earnings forecasts, strategies, policies and targets appears as a forward-looking statement. Such statements are made on the grounds of a plan, expectation or decision made based on the information obtained at the time and certain assumptions deemed logical, while actual earnings results and other disclosed future information may vary greatly due to various risks and uncertainties. - Quiet Period
In order to ensure fairness to every investor, we have defined the quiet period as the time starting from the day after the final day of each corresponding quarter until the day of our earnings announcement. During this period, we will refrain from responding to or making comments on questions related to our account settlement and earnings forecast. However, if a large discrepancy from the earnings forecast is found in the quiet period, information will be appropriately disclosed following the Timely Disclosure Rules. - Development of Internal Systems/Structures
Through the appropriate management of our disclosure policy, we establish and maintain a system that allows us to disclose information in a timely and appropriate manner following the Timely Disclosure Rules. We have clearly defined* the processes from when information originates to its disclosure in order to exercise information disclosure grounded in appropriate decision-making as a company. Based on this, the department responsible for information disclosure appropriately collects and analyzes information through coordination with each business department.
