Disclosure Policy

As a rule, Penta-Ocean Construction Co., Ltd. (“the Company”) discloses corporate information in a timely and appropriate manner, respecting the standpoint of our shareholders and investors. The Company discloses material business, operation and earnings information that may have an impact on investment decisions, as required under the timely disclosure rules established by the securities exchange. We proactively disclose other information that, while not necessarily mandated under timely disclosure rules, nevertheless provides useful information to our shareholders and investors. At the same time, the Company is committed to maintaining ongoing communications with our stakeholders as a whole, in keeping with our information disclosure responsibility as a corporate citizen.

The Company is actively engaged in investor relations (IR) activities, reflecting our belief that the appropriate disclosure of information to analysts facilitates evaluations and other analyses for the market, contributing to the formulation of a rational and efficient share price.

The Company discloses material information subject to timely disclosure rules according to the rules established by the securities exchange. Information is disclosed via registration with the “TDnet System” provided by the Tokyo Stock Exchange. As a rule, the Company provides identical information to news outlets promptly after registration, and publishes the same information and materials on the corporate website.

When disclosing information not subject to timely disclosure rules, the Company expends its best efforts to ensure that such information is fairly communicated via corporate website and media outlets.

In accordance with the timely disclosure rules established by the securities exchange, the Company offers timely disclosure of information related to material Company or subsidiary decisions, facts or financial matters as they occur. The Company also offers timely disclosure in response to inquiries from the securities exchange with respect to previously disclosed information and/or news reports, as well as for information associated with changes or cancellations of material Company information previously disclosed.

In addition to earnings projections noted in financial briefings or other reports, the Company may provide information related to future events or opinions regarding the future (“Future Projections”). Printed materials, briefings, documents and question-and-answer sessions provided by the Company may include Future Projections. Future Projections are based on decisions made in light of conditions at the time. Accordingly, the Company may change Future Projections without prior notices when changes to previously assumed circumstances occur. Actual earnings may differ from Future Projections due to various factors. Please see “Disclaimers” for more.