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| LAWSON, INC. (hereinafter "the Company") has formulated Basic Principles for Information Disclosure (hereinafter "the Principles") based on its basic internal regulations governing information disclosure to discharge its corporate social responsibilities (CSR) and corporate governance. The Principles, which can be found on this website at http://www.lawson.co.jp/index.html, express the Company's thinking regarding information disclosure. |
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| 1. |
Basic Policy on Information Disclosure |
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The Company fully appreciates that the timely and appropriate disclosure of corporate information is one of the building blocks of sound capital markets and the basis upon which customers use LAWSON stores with peace of mind. The Company, therefore, works to disclose Important Information, as defined in Paragraph 2 below, in an appropriate, timely and fair manner to capital market participants, such as investors and analysts, and news organizations, in conformity with relevant laws and ordinances, including the Corporate Law and the Securities and Exchange Law of Japan, as well as stock exchange regulations (hereinafter "the Regulations)." In doing so, the Company aims to garner even greater trust and earn a fair evaluation of its corporate value in capital markets. |
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| 2. |
Objective and Scope of Application |
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| (1) Objective |
| The Principles stipulate the necessary requirements and procedures for information disclosure to achieve the basic policy mentioned in the preceding paragraph. Furthermore, as well as serving as the Company's internal regulations, the Principles publicly clarify the Company's approach to disclosure to capital market participants and news organizations. |
| (2) Scope of Application |
| The Principles are applicable to all Company employees, namely directors, full-time employees, temporary employees, seconded employees and other personnel with equivalent status.
The following types of information are subject to the Principles (hereinafter "Important Information"). |
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| 3. |
Basic Principles on the Disclosure of Important Information |
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The Company will adhere to the following basic principles in disclosing Important Information.
| (1) Transparency and Accountability |
| The Company will work to ensure transparent disclosure based on the facts, regardless of whether they are advantageous or disadvantageous to the Company, and fulfill its accountability obligations. |
| (2) Compliance With Relevant Laws, Ordinances and Regulations |
| The Company will satisfy the requirements of generally established standards such as relevant laws and ordinances, including the Securities and Exchange Law of Japan, and stock exchange disclosure regulations. |
| (3) Timely Disclosure |
| The Company will disclose information in a timely manner following the occurrence of facts that require disclosure. |
| (4) Understandable Disclosure Information |
| The Company will work to disclose information that is easy to understand in consideration of communication with customers and not just capital market participants. |
| (5) Fairness |
The Company will work to ensure that information is disseminated fairly to capital market participants. |
| (6) Confidentiality |
| The Company will strictly manage Important Information and undertake not to disclose information to third parties (including directors and employees of the Company), except in cases where confidentiality is guaranteed by a non-disclosure agreement or other means, until appropriate and fair disclosure is made. |
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| 4. |
Response to Market Rumors |
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| (1) Response to Market Rumors |
| The Company's basic policy is to refrain from commenting on market rumors. However, where the Company decides that a market rumor may have a material effect on capital market participants and/or the Company, and/or the Company receives a request from a stock exchange, an appropriate public response will be made. |
| (2) Dealings With Third Parties |
| In cases where business dealings with third parties fall within the definition of Important Information, prior agreement regarding the disclosure of information relating to said dealings will be decided in advance with the other party. |
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| 5. |
Stipulation of a Quiet Period |
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| (1) |
To ensure fairness and prevent the leak of earnings information, the Company stipulates a so-called "Quiet Period," as specified below, prior to earnings announcements. During this period, the Company refrains from commenting on earnings forecasts. However, if during this Quiet Period the Company deems there is Important Information, as defined by the Company, that is, information to which stock exchange timely disclosure rules apply or information that could affect the investment decisions of investors (for example, a major difference between the latest earnings forecasts and previous earnings forecasts), the Company will disclose that information. |
| (2) |
The Quiet Period for Q2 and full-year earnings releases shall commence 5 business days before the period-end and conclude on the day of the said earnings announcement.
The Quiet Period for Q1 and Q3 earnings releases shall commence 10 business days before the earnings announcement and conclude on the day of the said earnings announcement.
The Quiet Period shall be stipulated at the discretion of the Company, taking into consideration current conditions in the capital market and the Company's schedule for the preparation of earnings results. The period may be revised depending on changes in internal and external environments. Any change shall be announced immediately via the Company's website. |
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