Disclosure Policy

Tokuyama took steps to put in place Tokuyama Group Guidelines for Business Activities , which were ratified by the Board of Directors in March 2012. Turning to Part IV of these guidelines, the Company identified certain stipulations governing its relationships with shareholders and investors and clarified its basic stance toward the disclosure of information.


Part IV of the Tokuyama Group Guidelines for Business Activities

IV. Relationships with Shareholders and Investors


1. The Proper, Timely and Easy-to-understand Disclosure of Information
The Company shall make every effort to ensure the proper, timely and easy-to-understand disclosure of information to society at large beginning with its shareholders and investors. Extending beyond the Company’s operations, performance, and financial standing, this information will cover such wide-ranging fields as the Company’s products and services as well as non-financial data including contributions to the environment and society.


2.Insider Trading Prevention
The Company shall make every effort to prevent the purchase and sale of marketable securities including shares as well as the granting of gains, favors, or benefits to a third party on the basis of undisclosed information obtained either within or outside the Group pertaining to business operations and transactions.

Internal Structure for Timely Disclosure

Based on its timely disclosure rules and regulations, the disclosure of information pertaining to the Company and its subsidiary companies with respect to:
a) decisions of fact:
b) incidents of fact, and:
c) financial results:
shall be undertaken in accordance with the following process and flow.


a) Disclosure of information pertaining to decisions of fact:
Departments that put forward important matters for ratification by such decision-making bodies as the Board of Directors shall forward the item in advance to the officer responsible for the handling of information. The officer responsible for the handling of information shall determine whether or not the item is a matter that requires disclosure. In the event that disclosure is deemed necessary, the item shall be presented to the officer responsible for information disclosure and disclosed after ratification by such decision-making bodies as the Board of Directors. The department governing subsidiaries  shall also follow the same procedure for subsidiary company information.


b) Disclosure of information pertaining to incidents of fact:
Departments involved in major incidents of fact shall report to the officer responsible for the handling of information. The officer responsible for the handling of information shall determine whether or not the item is a matter that requires disclosure. In the event that disclosure is deemed necessary, the item shall be presented to the officer responsible for information disclosure and disclosed. The department governing subsidiaries  shall also follow the same procedure for subsidiary company information.


c) Disclosure of information pertaining to financial results and other important information:
The Financial Reporting Committee , which is chaired by the director overseeing the Corporate Administration Division, is charged with the responsibility of carrying out operations relating to the Company’s financial reporting. This committee is made up of members from various areas within the Company including the Management Support Center , the Corporate Planning Division, and the General Affairs Department. In this manner, steps have been taken to put in place a framework under which the Company undertakes both internal and mutual reviews within and between departments that comprise the committee.
The Financial Reporting Committee Secretariat  is charged with the responsibility of seeking approval to the disclosure of financial results and related information from the Board of Directors and Management Committee Secretariat . While the Financial Reporting Committee Secretariat  puts forward matters for discussion to the Board of Directors, agenda items are forwarded to the officer responsible for the handling of information in advance. Item are then presented to the officer responsible for information disclosure by the officer responsible for the handling of information and disclosed after ratification by the relevant decision-making body.
Meanwhile, members of the Audit & Supervisory Board, independent auditors, and the Auditing Department are responsible for ensuring that financial reporting operations are conducted in a proper manner while undertaking audits during each period.


* The General Manager Corporate Communications & Investor Relations Dept. is the officer responsible for the handling of information.
* The head of the division governing the Corporate Communications and Investor Relations Dept.  is the officer responsible for information disclosure.

Top Page