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.

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 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. 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 and Supervisory Committee, 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.

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.