Disclosure Policy

1. Information Disclosure Basic Policy

The basic policy of Tsubakimoto Chain, Co. (the “Company”) is to comply with laws and regulations as well as corporate ethics, and to continuously disclose information to its shareholders, investors, and all other stakeholders in a timely, accurate, fair, and proactive manner.

2. Information Disclosure Standards

The Company promptly discloses information subject to laws and regulations as well as the rules on timely disclosure stipulated by the Tokyo Stock Exchange (hereinafter the “Timely Disclosure Rules”). In addition, the Company endeavors to proactively disclose information that is not subject to the above but is judged by the Company to be useful to its shareholders, investors, and all other stakeholders.

3. Information Disclosure Methods

The Company posts information subject to laws and regulations as well as the Timely Disclosure Rules on its website promptly after releasing it on the information disclosure system designated thereby. Also, the Company discloses information that is not subject to the above but judged by the Company to be useful to its shareholders, investors and all other stakeholders through its website, or other means, in an accurate and fair manner.

4. Fairness of Information Disclosure

The Company strives to properly manage and fairly disclose undisclosed important information that has a significant effect on investment decisions. However, should any undisclosed important information be communicated only to a certain business partner, the Company will take measures in accordance with the fair disclosure rules set forth in the Financial Instruments and Exchange Act.

5. Stance on Future Outlook

The Company discloses information concerning earnings forecasts and future outlook based on information available to the Company and certain assumptions that it considers reasonable at the time of disclosure. Accordingly, the Company makes disclosures by alerting readers to the effect that actual performance may differ from such forecasts due to various factors. Further, if there is a change in information concerning earnings forecasts and future outlook disclosed by the Company, necessary information will be disclosed in accordance with the Timely Disclosure Rules.

6. Silent Period

To prevent the leakage of financial information and ensure fairness, the Company maintains a silent period from the date following the settlement date to the announcement date of financial results. During this period, the Company refrains from replying to questions or commenting on the financial results and earnings outlook. However, if the Company anticipates that results will vary significantly from earnings forecasts during the silent period, it will make prompt disclosure in accordance with the Timely Disclosure Rules.

Established: April 28, 2008
Revised: January 22, 2019

Toward a Sustainable Society

The Tsubaki Group is engaged in the “art of moving” and aims to provide value that exceeds expectations
to become a company that continues to be needed by society.