Disclosure Policy

Basic Policies

RENOVA, Inc. and its affiliates (hereinafter referred to as the “RENOVA Group”) lay down Disclosure Policies for the RENOVA Group as provided below in order to enable their shareholders and investors to correctly understand the RENOVA Group and form appropriate investment decisions. These Disclosure Policies are aimed at timely, appropriate and fair disclosure of information.

Criteria for Information Disclosure

The RENOVA Group shall continue to disclose information speedily based on the principles of transparency, fairness and accuracy in accordance with various laws, including the Financial Instruments and Exchange Act, and the Securities Listing Regulations and the Enforcement Rules for Securities Listing Regulations prescribed by the Tokyo Stock Exchange (hereinafter referred to as the “Securities Listing Regulations, etc.”). The RENOVA Group shall also strive to proactively and fairly disclose information not corresponding to material facts prescribed in the Financial Instruments and Exchange Act and to items under disclosure obligation prescribed in the Securities Listing Regulations, etc. to the extent possible when RENOVA, Inc. (hereinafter referred to as the “Company”) judges such information to be useful to RENOVA Group shareholders and investors.

Information Disclosure Methods

The RENOVA Group shall observe the Securities Listing Regulations, etc. with regard to the disclosure of corporate information corresponding to items subject to disclosure obligation prescribed therein (hereinafter referred to as “Disclosure Items”). The RENOVA Group shall publish Disclosure Items through the timely disclosure system offered by the Tokyo Stock Exchange (hereinafter referred to as the “TDnet”). The RENOVA Group shall also publish Disclosure Items at the official website of the Company after their disclosure through the TDnet. Further, the RENOVA Group shall speedily disclose information not corresponding to Disclosure Items in appropriate ways as the occasion demands in accordance with the degrees of its importance and urgency when the information may to influence investment decisions.

Quiet Periods (Voluntary Restraint Periods for Investor Relations Activities)

The RENOVA Group sets the several weeks prior to the announcement of their operating results as quiet periods to prevent the leakage of financial closing information and to ensure fairness. The RENOVA Group shall refrain from making comments and answering inquiries about their account settlement during these periods. However, the RENOVA Group shall disclose information as necessary in cases where an event that occurs during these quiet periods is subject to timely disclosure (including cases where it becomes clear that differences from results forecasts correspond to the range of fluctuations within the purview of disclosure requirements prescribed in the Securities Listing Regulations, etc.). The RENOVA Group shall answer during the quiet periods inquiries made by shareholders and investors in connection with information published in the past.

Prospects for the Future

Information disclosed by the Company other than facts in the past, such as plans, forecasts and strategies, are prospects for the future which the Company assumes based on the information available at the time of disclosure. As such, this information involves risks and uncertainties associated with factors that include economic conditions, market trends, and changes in tax and other systems. These factors may make actual results and other information the Company will announce in the future different from said information.