Disclosure Policy

Tokuyama clarifies its basic stance on information disclosure as a company in Chapter 6 Communication of the Tokuyama Group Code of Conduct.

Tokuyama Group Code of Conduct Chapter VI

VI. Communication

We disclose information in a timely and appropriate manner to all stakeholders and build relationships of trust with them through ongoing dialogue.

  • Ⅰ) We actively disclose the status of our corporate activities in a fair manner, including financial and non-financial information, and we strive to maintain good communication with the broader society.
  • Ⅲ) We never engage in insider trading using significant confidential information that has not been released publicly.
Policy on Communication with Shareholders

The section chief of the Corporate Communication and Investor Relations Department will take the role of promoting constructive dialogue with shareholders and investors.


The Corporate Communication and Investor Relations Department works closely with other internal departments, including the Corporate Strategic Planning Department , the Corporate Accounting Department, the Finance and Investment management Department, the Corporate Social Responsibility Planning Department, the General Affairs Department, the Research and Development Division, and business divisions in the planning and promotion of dialogue.


In regard to IR activities in which executives communicate with shareholders and investors directly, the Company holds a results briefing session for analysts and institutional investors four times a year, and participates in conferences and small meetings held by securities firms whenever necessary. The Corporate Communication and Investor Relations Department, which is in charge of IR activities, holds interviews with institutional investors inside and outside Japan, as well as sessions for introducing the Company to individual investors.


The opinions and views of shareholders and investors received through dialogue are confirmed and shared at our IR meetings, which are attended by executives and relevant section chiefs. The subsequent IR report is then distributed to each section within the Company to provide feedback, and is used to formulate and revise management and business strategies with the goal of improving corporate value.


In regard to the management of insider information, the Company has formulated in-house rules and ensures comprehensive management through non-disclosure agreements and other measures.

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.
In addition, the Auditing Department conducts audits of the timely disclosure system as necessary.

  • a) Disclosure of information pertaining to decisions of fact:
    The secretariat of the Board of Directors, etc., sends the agenda of important matters to be resolved at the Board of Directors, etc., to the Corporate Communications & Investor Relations Department in advance. The Corporate Communications & Investor Relations Department 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 head of the division with jurisdiction over the Corporate Communications & Investor Relations Department 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 Corporate Communications & Investor Relations Department. The Corporate Communications & Investor Relations Department 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 head of the division overseeing the Corporate Communications & Investor Relations Department 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 Planning 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 departments and divisions. 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. While the Financial Reporting Committee Secretariat puts forward matters for discussion to the Board of Directors, agenda items are forwarded to the Corporate Communications & Investor Relations Department in advance. Items are then presented to the officer responsible for Corporate Communications & Investor Relations Department by Corporate Communications & Investor Relations Department and disclosed after ratification by the relevant decision-making body.
Process for the Timely Disclosure (Flow Chart)
Quiet Period

To ensure fair disclosure and prevent the leakage of financial information, Tokuyama has adopted a quiet period that extends from 5 business days before the final day of each quarter to the date of financial results announcement. During this quiet period, the Company will refrain from commenting on or responding to inquiries regarding financial information. However, should the possibility of a major discrepancy from previously announced earnings forecasts arise during the quiet period, Tokuyama will make an announcement in accordance with Timely Disclosure Rules.


As an exception, the Company will respond to inquiries and respond to interviews during the quiet period that fall within the scope of such qualitative information as previously announced information, management policies, and business overviews.

Efforts for Active General Shareholder Meetings and Efficient Exercise of Voting Rights
Early Notification of General Shareholder Meeting The Company released the convocation notice for the 160th Ordinary General Shareholder Meeting held on June 25, 2024, 33 days prior to the meeting on TDnet of Tokyo Stock Exchange, Inc., and on the Company's website.
Scheduling AGMs Avoiding the Peak Day The Company holds general shareholder meetings on days other than the peak day to ensure that as many shareholders as possible can attend the meeting.
Allowing Electronic Exercise of Voting Rights Voting rights may be exercised electronically via personal computers on the website for the exercise of voting rights designated by the Company's shareholder registry administrator.
Participation in Electronic Voting Platform The Company participates in the Electronic Voting Platform for Institutional Investors provided by ICJ Inc.
Providing Convocation Notice in English The Company prepares a notice of convocation (summary) in English and discloses it on its webpage.
Other Questions were accepted in advance at the 160th Ordinary General Meeting of Shareholders held on June 25, 2024.
IR Activities
Regular Investor Briefings for Individual Investors The Company holds briefing sessions for individual investors several times a year. In addition, its websites are dedicated to individual investors, with the aim of providing easy-to-understand summaries of materials relating to company briefings and company information.
Regular Investor Briefings for Analysts and Institutional Investors The Company holds results briefing sessions or conference calls via the telephone network for institutional investors four times a year when it announces the quarterly results. It also holds briefing sessions and small meetings on medium-term management plans, factory tours, etc. for institutional investors from time to time.
Posting of IR Materials on Website The Company posts earnings reports, annual securities reports, documents related to general shareholder meetings, integrated report, presentation materials and videos for results briefing meetings and the main questions and answers, and business results and financial data on Excel, etc. In addition, IR materials in English (with the exception of certain materials) are posted at the same time as the Japanese versions.
Establishment of Department and/or Manager in Charge of IR The Company has a dedicated team for IR activities in Corporate Social Responsibility Division, Corporate Communications and Investor Relations Department. In implementing IR activities, the Company strives to maintain timely, appropriate and comprehensible disclosure of information through close coordination between the senior management, the Corporate Planning Division, the business divisions and other departments of the Company.