Fundamental Policy

JAPAN MATERIAL Co., Ltd. (the "Company") strives to ensure the prompt disclosure of information based on a fundamental commitment to fairness and accuracy so that its shareholders and investors can clearly understand the JM Group and make appropriate investment decisions. The Company's information disclosure conforms to the laws and regulations laid out in the Financial Instruments and Exchange Act as well as the Securities Listing Regulations and the Enforcement Rules for Securities Listing Regulations (the "Securities Listing Regulations, etc.") established by the Tokyo Stock Exchange and any other stock exchanges on which the Company's stock is listed. The Company also seeks to proactively and fairly disclose information that it considers to be useful to shareholders and investors wherever possible, even if that information is not required to be disclosed under the important facts stipulation in the Financial Instruments and Exchange Act or the disclosure obligations in the Securities Listing Regulations, etc.

Method of Disclosure

Any corporate information that is judged an obligatory disclosure item under the Securities Listing Regulations, etc. will be disclosed via the Timely Disclosure network (TDnet) provided by the Tokyo Stock Exchange. The Company will publish that same information on its website once it has been disclosed through TDnet. Any information that does not fall under the obligatory disclosure items but that the Company judges may impact investment decisions will be disclosed promptly depending on its significance and urgency.

Quiet Periods (Refrain from IR Activities)

The Company observes a quiet period, which extends from the day after the completion of a business year or quarter until the announcement of the financial results for that period. In order to prevent any leakage of the financial results and ensure fairness, the Company refrains from making any comments or accepting any enquiries pertaining to financial results during the quiet period. However, if timely information disclosure is required during the quiet period (for instance, if the difference between the Company's actual business results and business estimates is clearly going to be of a magnitude comparable to that stipulated as requiring disclosure under the Securities Listing Regulations, etc.), then the Company will disclose that information in accordance with the disclosure regulations. The Company can respond to questions from shareholders and investors during the quiet period if those questions relate to information that has already been published.

Future Outlook

Some of the information that the Company discloses, such as plans, forecasts, or strategies that are not derived entirely from past facts, are forward-looking future outlooks made by the Company based on available information at the time. As such, that information includes uncertain elements and risks relating to potential changes in economic conditions, market trends, or tax and other systems. As a result, these outlooks may differ from actual future business results due to these various influencing factors.