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Disclosure Policy

1.Basic Policy

   SMK Corporation shall disclose its financial affairs, performance, business activities, ESG activities, and other management information to shareholders, investors, and other stakeholders in a timely and appropriate manner in line with the SMK Group Charter for Corporate Behavior and the SMK Group Code of Conduct that set forth compliance with laws and international rules and socially responsible behavior. At the same time, SMK shall clearly convey the SMK philosophy and management policy to stakeholders, take opinions and criticisms of those seriously, and strive to make use of them in its business activities.

2.Disclosure Criteria

   SMK shall disclose information according to the Companies Act, the Financial Instruments and Exchange Act and other relevant laws/ordinances, and the Timely Disclosure Rules stipulated by the Tokyo Stock Exchange on which its shares are listed. Moreover, SMK proactively discloses information that it determines to be useful in understanding the company even when that information does not fall under the Timely Disclosure Rules.

3.Disclosure Method

   SMK shall disclose information subject to the Timely Disclosure Rules on TDnet of the Tokyo Stock Exchange and disclose annual securities reports and other reports based on the Financial Instruments and Exchange Act on EDINET of the Financial Services Agency. The disclosed information will also be promptly posted on the company’s website. In addition, SMK widely discloses information that does not fall under the Timely Disclosure Rules to the general public through the media and on the company’s website.

4.Prevention of Insider Trading

   In order to ensure the appropriate management of the insider information of the company, its subsidiaries, and other companies by officers and employees, and to prevent insider trading, SMK has established internal regulations and are making sure that everyone is fully aware of them.

5.Future Prospects

   Information relating to future prospects (e.g., earnings forecasts, strategies and policies) disclosed by SMK is based on information available at the time of its creation and certain assumptions considered to be reasonable. Actual performance may vary greatly due to various risks and uncertainties.

6.Quiet Period

   In order to prevent the leakage of financial information and to ensure fairness in information disclosure, SMK has established a quiet period from the day after each quarterly accounting period date to the day of the announcement of the financial results for the applicable quarter. The company refrains from answering questions or making comment on those financial results during this period. Nevertheless, in the event that a major difference will arise between the earnings forecast and actual performance, SMK shall disclose that information in a timely manner according to the Timely Disclosure Rules even during the quiet period.