Other IR InformationDisclosure Policy

(1) Information Disclosure Standards

Seibu Giken Co., Ltd. (hereinafter called “the Company”) discloses information promptly, accurately, impartially, and continually, in accordance with the Financial Instruments and Exchange Act and other laws and regulations, and the “Timely Disclosure of Corporate Information, etc.” (hereinafter referred to as the “Timely Disclosure Rules”) of the Securities Listing Regulations issued by the Tokyo Stock Exchange. Even in cases not covered by laws and regulations or the Timely Disclosure Rules, the Company actively and fairly discloses information that the Company deems important or useful for shareholders and investors to understand the Company. The Company does not disclose any personal information, customer information, or information that may infringe on the rights of related parties.

(2) Information Disclosure Procedures

The Company discloses information required by the Timely Disclosure Rules through the Timely Disclosure Network (TDnet) provided by the Tokyo Stock Exchange in accordance with the Rules, and shall also promptly post on the Company’s website after being disclosed through TDnet. The Company also discloses information that is not subject to the Timely Disclosure Rules, if deemed to be important or beneficial for shareholders and investors, by posting it on the Company’s website, etc.

(3) Prevention of Insider Trading

As for the prevention of insider trading, etc., the Company established the company policies such as Information Security Management Regulations and Insider Trading Prevention Regulations and strives to prevent the occurrence of such transactions. In addition, the Company holds in-house training sessions on Insider Trading Regulations for directors, executive officers, and employees every year to ensure that they are fully aware of and understand the purpose of the regulations, and also issues internal notices about this matter as appropriate to alert them.

(4) Handling of Earnings Forecasts and Forward-Looking Statements

The earnings forecasts, future prospects, strategies, goals, and other statements disclosed by the Company, other than those relating to past or present facts, are forward-looking statements, and they are on the basis of plans, expectations, and judgments based on information available to the Company at present and certain assumptions that the Company considers reasonable. Therefore, actual results, etc., may differ from disclosed earnings forecasts, etc., due to variable factors of various uncertainties such as economic conditions, etc.

(5) Quiet Period

In terms of preventing leakage of financial information (including quarterly financial information) and ensuring fairness in information disclosure, the Company sets a period from the day following the end of a fiscal period (fiscal quarter) to the day of the announcement of financial results as a “Quiet Period.” Within this period, the Company refrains from responding and making comments on questions about financial results and earnings forecast. However, if the Company anticipates a significant change in earnings forecasts during this period, the Company shall make an announcement as appropriate in accordance with the Timely Disclosure Rules.

(6) Development of Company Structures

In compliance with this Disclosure Policy, the Company strives to develop and maintain company structures in order to conduct appropriate information disclosure under laws and regulations and the Timely Disclosure Rules.