Disclosure Policy
Basic Policy on Information Disclosure
Pole To Win Holdings (the “Company”) recognizes that the disclosure of information regarding material facts about the Company is fundamental to investor confidence and will make accurate, fair, timely, and appropriate disclosure in accordance with the Financial Instruments and Exchange Act and other relevant laws and regulations, as well as the rules of the Tokyo Stock Exchange.
Purpose
This policy sets forth the requirements and principles for the disclosure of information regarding material facts that investors should consider when making investment decisions in accordance with the above. While serving as a guideline applicable to the officers and employees of Group companies, this policy is also intended to express our stance on information disclosure to investors to outside parties.
Disclosures and Disclosed Acts
The disclosures and disclosed acts covered by this policy are as follows:
i.Legal disclosure
Information disclosure required by the Financial Instruments and Exchange Act, the Companies Act, and related laws and regulations shall be properly disclosed in accordance with the requirements and methods stipulated in those laws and regulations.
ii.Timely disclosure
Information required to be disclosed by the Timely Disclosure Rules of the Tokyo Stock Exchange, on which the Company is listed, shall be properly disclosed in accordance with the requirements and methods stipulated in the rules.
iii.Other disclosures
Regarding the information described in i and ii above, the Company shall promptly post the information on its website after the information is disclosed in accordance with laws and regulations and the Timely Disclosure Rules. In addition, the Company shall not only strive to disclose information not only within the scope of information required by laws and regulations and the Timely Disclosure Rules, but also actively disclose information that is important for investors to make appropriate investment decisions to the greatest extent possible. Information other than that required by laws and regulations and the Timely Disclosure Rules shall be disclosed appropriately, such as by distributing news releases or posting materials on the Group’s website.
Basic Requirements for Information Disclosure
The Company shall provide information disclosure that meets the following requirements:
i.Fair disclosure
The Company will not disclose non-public information of a material nature to specific individuals before its release to the public.
ii.Transparent disclosure
The Company will fulfill its accountability by providing factual explanations, regardless of whether the material information is advantageous or disadvantageous to the Group.
iii.Timely disclosure
The Company shall establish procedures for information disclosure and promptly determine and disclose material information.
Principles of Information Disclosure
The Company shall disclose information based on the principles below.
i.Materiality of information
The Company classifies “material information” not only as information defined by relevant laws and regulations and the Timely Disclosure Rules but also as information likely to significantly impact investors’ decision-making. The Company’s Administrative Department shall voluntarily establish disclosure standards broader than the minor standards of the Timely Disclosure Rules to guide its judgment of materiality.
ii.Confidentiality of information
Confidential information shall be held in strict confidence until it is appropriately and fairly disclosed. When disclosing confidential and material information, the Company may temporarily withhold disclosure within the scope of laws, regulations, and the Timely Disclosure Rules if it believes that premature disclosure would harm the interests of its shareholders.
iii.Forward-looking statements
Information disclosed by the Company regarding future plans, forecasts, strategies, and other forward-looking statements is based on assumptions and suppositions that the Company independently deems reasonable at the time of disclosure. Accordingly, such information contains risks and uncertainties. When making forward-looking statements, the Company adds that the information is subject to change.
iv.Quiet period
To maintain fairness in disclosure to investors, the Company shall observe a quiet period from the day following the last day of each fiscal period to the day before the announcement of financial results. During this time, the Company shall refrain from commenting on or responding to questions concerning financial results. Even outside the quiet period, the Company shall refrain from so-called “preview interviews” regarding financial results or dialogue regarding unpublished earnings forecasts.
Established: November 19, 2024
Pole to Win Holdings Inc.
Teppei Tachibana, President and CEO