Disclosure Policy

established:April 25,2017

1. Basic policy

Aiming at “the realization of efficient, healthy and transparent management”, NICHIDAI CORPORATION (“Company”) considers active information disclosure as its basic policy. To ensure that Company’s stakeholders including its shareholders and investors deeply understand it, it works on the disclosure of information specified in laws and regulations such as Companies Act, Financial Instruments and Exchange Act as well as “Rules on Timely Disclosure of Corporate Information by Issuers of Listed Securities” (“Timely Disclosure Rules”) Tokyo Stock Exchange has set. The Company also actively and fairly discloses other information it determines as important for those stakeholders to understand it.

2. How to disclose information

Any information specified in Timely Disclosure Rules is disclosed in Timely Disclosure Network (TDnet) provided by Tokyo Stock Exchange in accordance with the Rules. In principle, any disclosed information is immediately posted on the Company’s website. The Company also posts other information that is not specified in Timely Disclosure Rules but it determines as important or useful on its website.

3. Prevention of insider trading

For the prevention of insider trading, the Company has established its rules for the prevention of insider trading.

4. Quiet period

To prevent the leakage of accounting information (including quarterly account settlement) and ensure fairness, the Company sets the period from the day after the final day of the fiscal year to the date of announcement of financial results as its quiet period. In this period, the Company refrains from providing any responses or comments on questions about its financial results and business forecast. In case it is expected that the Company’s business forecast significantly varies in this quiet period, it discloses that fact in accordance with Timely Disclosure Rules.

5. Prospects for future performance

The Company also discloses information about its future such as its business plan, prospects for performance and strategy. These kinds of information are based on the Company’s judgment and assumption in view of the information currently available to it. Since they include various uncertainties, the actual performance may differ from the prospects as a result.

6. Development of internal operational system

In accordance with this disclosure policy, the Company is committed to the development and enhancement of its internal operational system to ensure appropriate information disclosure in conformity with Timely Disclosure Rules and applicable laws.

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