Disclosure Policy

1.Basic policy

In order to establish and maintain relationships of mutual trust with all our stakeholders including shareholders and investors, Nippon Engineering Consultants discloses corporate information such as the contents of our group’s business and business activities in accordance with relevant laws such as the Companies Act and the Financial Instruments and Exchange Act and the legislation and rules on timely disclosure established by the Tokyo Stock Exchange (hereinafter referred to as the Timely Disclosure Rules). In addition, we will ensure the accuracy of disclosed corporate information at all times, and will provide information in a timely, appropriate and fair manner.

2.Information disclosure methods

Information that requires disclosure based on the Timely Disclosure Rules will be disclosed using the Company Announcements Disclosure Service (TDnet) provided by the Tokyo Stock Exchange. Also, after disclosure by this system, information will be posted on our website as soon as possible. In addition, regarding information other than the information required by the Timely Disclosure Rules, if we judge that the information is useful to deepen the understanding of all stakeholders, we will disclose it by an appropriate method such as posting it on our website.

3.Enhancing communication and feedback

In addition to timely disclosure and information dissemination through our website, etc., we will strive to provide comprehensive direct communication by holding investor meetings for institutional investors and analysts, conducting questionnaires for all shareholders, and responding to daily inquiries. With regard to opinions and requests received from shareholders and investors, we will share the information with the Board of Directors and make it a reference for corporate management to improve corporate value.

4.Person responsible for information disclosure

In principle, the General Manager of the Management Division and the IR Department (Corporate Planning Office) will deal with individual external inquiries and interviews such as from the media or research organizations. In addition, when the contents of an inquiry or interview are specific and specialized, such as being related to technical, financial, or administrative matters, they will be dealt with by the officers or employees deemed to be appropriate.

5.Management of important information

With regard to important information such as insider information, we will endeavor to manage “important information” and “prevention of insider trading” by establishing internal regulations for handling of important information before publication and transactions such as stocks.

6.Setting of silent period

In order to prevent the leakage of settlement information and to ensure fairness of information disclosure, a fixed period of time from the day following the end of the fiscal year end (including the quarterly settlement of accounts) to the settlement announcement date shall be set as the “silent period.” During this period, we will refrain from commenting on questions regarding the settlement of accounts. However, even during the silent period, we may make timely disclosure regarding revisions to earnings projections and dividend forecasts, etc., in accordance with the Timely Disclosure Rules. In addition, we will respond to inquiries on information already published.

Established November 2015