Disclosure Policy

Revised on June 18, 2018

1.Purpose

This Disclosure Policy outlines the basic principles by which Alfresa Holdings Corporation (hereafter "the Company") discloses information to its shareholders and investors from the perspective of fair disclosure.

2.Basic Policy on Disclosure

In order to deliver appropriate information to its shareholders and investors, the Company discloses information in a timely manner, based on the principles of transparency, fairness, continuity, timeliness, and bidirectionality. Specifically, the Company discloses information in compliance with the Companies Act, the Financial Instruments and Exchange Act, and other laws and regulations, as well as the regulations on timely disclosure of corporate information stipulated in the Securities Listing Regulations of the Tokyo Stock Exchange (hereafter "timely disclosure regulations").
The Company also discloses information which, although not covered by the scope of various laws and regulations or timely disclosure regulations, it believes will be of benefit to shareholders and investors in a proactive and fair manner, via appropriate means.
However, this excludes information deemed to be inappropriate for disclosure, such as information that infringes on privacy.

3.Disclosure and Dialogue

This policy primarily applies to the following disclosure and dialogue.

1Statutory disclosure

1. Disclosure based on the Financial Instruments and Exchange Act
   Securities reports, quarterly reports, internal control reports, and extraordinary reports, etc.
2. Disclosure based on the Companies Act
   Convocation notice of general shareholders meetings, reference documents for general shareholders meetings, business reports, non-consolidated and consolidated financial statements, etc.

2Timely disclosure required by the Tokyo Stock Exchange

1. Material decision facts or occurrence facts
2. Financial information
3. Revisions to earnings forecast or dividend forecast, etc.
4. Other important information regarding the Company or its subsidiaries, etc.

3Other disclosure and dialogue

1. IR-related materials, such as financial results briefing materials, newsletters to shareholders, and integrated reports/annual reports
2. Voluntary disclosed materials, such as company profile
3. Website of the Company
4. All forms of communication with shareholders, such as general shareholders meetings, and inquiries by phone or e-mail, etc.
5. All forms of communication with security analysts and institutional investors, such as financial results briefings, one-on-one interviews, conference briefings, inquiries by phone or e-mail

4.Disclosure Method

Disclosures based on the Financial Instruments and Exchange Act shall be made through the Electronic Disclosure for Investors' NETwork (EDINET) operated by the Financial Services Agency, while disclosures required under the timely disclosure regulations of the Tokyo Stock Exchange shall be made through the Timely Disclosure network (TDnet) provided by the Exchange. In principle, all information disclosed through the above systems will also be posted on the Company's website. Information not classed as timely disclosure will also be disclosed in an accurate, prompt, and appropriate manner in accordance with the spirit of timely disclosure.

5.Material Information and Its Management

1Material information

In addition to information subject to disclosure under the Companies Act, the Financial Instruments and Exchange Act, etc., and the timely disclosure regulations of the Tokyo Stock Exchange, the Company will also manage "material facts under insider trading regulations" and “not yet open to public information of a precise nature concerning an issuer’s financial information which would likely have a material effect on the price of the issuers’ securities if made public” as material information in accordance with the Fair Disclosure Rules (hereafter "FD Rules") stipulated in the amendments to the Financial Instruments and Exchange Act of 2017, related Cabinet and Cabinet Office Orders and guidelines, etc.

2Management of material information

The Company does not communicate material information to third parties until it is disclosed to the public. The Company will restrict provision of material information to officers and employees to the minimum necessary in order to perform their duties, and handle material information based on a secured management system.
In the event that an officer or employee of the Company as defined in 6. (1) below involved in the disclosure of material information unintentionally communicates material information in the course of his or her duties to a party involved in a transaction, such as a financial instruments business operator (hereafter "related party" or “related parties”), as defined in the FD Rules, the Company shall promptly follow the internal processes related to disclosure of material information as defined in 6. (2) below, and publish it by any method such as website of the Company. In certain circumstances, the Company may refrain from disclosing such material information if the related party to whom the undisclosed material information has been communicated is under an obligation to maintain confidentiality and an obligation not to buy or sell the Company's securities based on a contract concluded with the Company or by law.

6.Internal Systems Related to Disclosure of Material Information

1Information providers

Regarding the disclosure of material information as stipulated in the FD Rules, the Company shall designate its officers and employees belonging to the information disclosure division (public relations and investor relations division) as the information providers.

2Internal processes related to the disclosure of material information

The information disclosure division will collect necessary information through cooperation with the relevant departments. If there is a possibility that this information may be classed as material information under the FD Rules, the contact person in the information disclosure division, who is the head of the public relations and investor relations division, shall report the information management officer who is the corporate officer with responsibility for oversight of information management. The information management officer, as necessary, shall convene a meeting of the disclosure committee, which shall be comprised of the representative director, the information management officer and the contact person in the information disclosure division in order to deliberate on the appropriateness, timing and content of the disclosure of the material information. The committee shall be administered by the contact person in the information disclosure division. If deemed necessary by the information management officer, approval given by the representative director and the information management officer can be substitute method of the disclosure committee meeting.
Details of the deliberations by the disclosure committee shall be submitted to the Board of Directors meeting by the information management officer or contact person in the information disclosure division, as appropriate. The secretariat of the disclosure committee is in charge of the public relations and investor relations division.

7.Forward-looking Statements

Information disclosed by the Company may contain forward-looking statements. Information other than historical facts are forecasts or strategies based on certain assumptions and include certain risks and uncertainties. Accordingly, actual results may not correspond to these forecasts due to various changes in the environment and other factors.

8.Response to Market Rumors

The Company maintains a basic policy of not commenting on market rumors, either positive or negative.
If it is determined that a rumor being spread may have a significant impact on the value of the Company's securities, the Company may, on occasion, disclose certain information after receiving communication from parties such as the Tokyo Stock Exchange. The method of disclosure applied in such instances shall follow that used for timely disclosure.

9.Quiet Period

In order to prevent the leakage of financial information and ensure fairness, the Company shall refrain from responding to comments and questions regarding its financial results during the quiet period, which extends from the day after the closing date of each fiscal quarter to the day of the announcement of financial results. However, if it becomes clear during the quiet period that there is a significant discrepancy between projected earnings and the previously announced earnings forecast, the Company shall disclose information as appropriate. The method of disclosure applied in such instances shall follow that used for timely disclosure.

10.Dialogue with Capital Markets

The Company shall designate the information management officer as the representative for dialogue with capital markets, and shall endeavor to make senior management available for dialogue within reasonable limits. The information management officer shall control the information disclosure division, which shall closely work with the relevant internal departments to promote dialogue through the opportunities outlined in 3. (3) 5. above and other methods, and shall report opinions and other relevant information obtained through dialogue with capital markets to senior management as appropriate.

11.Policy on Selective Disclosure

The Company conducts individual interviews and small-group meetings with security analysts, institutional investors, etc., in order to promote an appropriate understanding of the Group. These meetings are not held only with certain related parties with whom the Company has a business relationship, and no selective disclosure of material information shall take place during these meetings. In case the Company has had unintentional communication of undisclosed material information to a related party, we shall endeavor to disclose information in a fair, impartial and appropriate manner, by method such as defined in 5. (2) above and other methods.