Disclosure Policy

1. Purpose

Marubeni corporation sets a basic policy in respect of information disclosure to all our stakeholders, including investors, in order to disclose information concerning our Group appropriately.

2. Basic Policy of Disclosure

The following is our basic policy when we disclose information.

(1) Complying with Relevant Laws and Regulations
Comply with relevant laws such as Financial Instruments and Exchange Act and Companies Act and regulations of stock exchanges.

(2) Timeliness
Disclose without delay any facts found which should be disclosed.

(3) Transparency
Always disclose factual information regardless of its content.

(4) Accuracy
Disclose necessary and sufficient information without creating misunderstanding.

(5) Fairness
Disclose information by a method which is equally accessible to our stakeholders.

(6) Continuity
Maintain continuity for information content for disclosure.

(7) Confidentiality
No information is to be leaked to a third party before an official disclosure is made.

3. Applicable Information for Disclosure

This basic policy applies to the following information disclosure.

(1)Statutory Disclosure
1) Disclosure in accordance with Financial Instruments and Exchange Act

  • Disclosure of corporate information (securities reports, quarterly reports, internal control reports and extraordinary reports)
  • Disclosure of tender offer (tender offer notification and position statements)
  • Disclosure of large volume possession of shares (large shareholding reports and change reports)

2) Disclosure in accordance with Companies Act (financial statements, consolidated financial statements, business reports and supplementary schedules)

(2) Timeliness Disclosure
Disclosure in accordance with regulations of stock exchanges

  • Decision Information (issuance of stock, payback, dividends, mergers, company split, stock exchange, business transfer, acquisitions, business collaborations and tender offers)
  • Occurrence Information (loss or damage caused by disaster, arising lawsuits or court decisions, bad debts, suspension of trading with suppliers)
  • Financial Results Information (content of financial results, adjustments of business performance and dividends prospects)
  • Information of Subsidiaries and Affiliates
  • Corporate Governance Information

(3) Voluntary Disclosure
Integrated Reports/Annual Reports, Shareholders' Reports, Mid-term Management Plan

4. Disclosure Committee

A disclosure committee is to be set up in order to construct, maintain and control a proper information disclosure system. The committee has a chairman who is a representative director nominated by the Company President and is also controlled directly by the Company President. The disclosure committee operates and formulates general rules and basic policies for disclosure, constructs and adjusts the company structure concerning statutory disclosure and timeliness of disclosure, as well as decides the significance and validity of statutory disclosure and the timeliness of such disclosure.

5. Other

(1) Dealing with Rumors in the Market
As a general rule, Marubeni shall not make any comments concerning inquiries regarding rumors in the market.
However, appropriate measures such as releasing voluntary news shall be taken if such rumors can have a significant impact upon Marubeni should they be ignored.

(2) Handling of Future Prospect Information
In order for our investors to evaluate our business and future management performance appropriately, a note is included that the actual results in the future may differ from the information of such performance prospects and other future prospects for publication of information concerning performance prospects and other future prospects.

Information Disclosure System Diagram

(1)Information gathering process
Officers responsible for information disclosure gather information and report information requiring timely disclosure when uncovered to the Corporate Communications Department (department in charge of information disclosure).
The Corporate Communications Department reports all information requiring timely disclosure to the Corporate Accounting Department in charge of provisional financial reporting.

(2)Analysis and appraisal process
The necessity to disclose information is discussed and confirmed with the relevant divisions and departments.
If necessary the matter is brought up for discussion by the Disclosure Committee.
Important matters are brought up for resolution by the Corporate Management Committee and Board of Directors.

(3)Disclosure process
Pending approval by the director of the Corporate Communications Department, and resolution by the Corporate Management Committee and the Board of Directors on important matters, information for disclosure is submitted to securities exchanges via TDNET.

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