Disclosure Policy

1. Purpose

Marubeni Corporation (the Company) has a basic policy on information disclosure to all our stakeholders, including investors, regarding the appropriate disclosure of information concerning our Group.

2. Basic Policy of Disclosure

The following is our basic policy when we disclose information.

(1) Complying with Relevant Laws and Regulations
Comply with relevant laws such as Financial Instruments and Exchange Act and Companies Act and regulations of stock exchanges.

(2) Timeliness
Disclose in a timely manner without delay any facts which should be disclosed when found.

(3) Transparency
Always disclose factual information regardless of its content.

(4) Accuracy
Disclose necessary and sufficient information without creating misunderstanding.

(5) Integrity/Fairness
Consistently disclose information by a method which is equally accessible to our stakeholders, while giving full consideration to prevent any selective disclosure.

(6) Continuity
Maintain continuity of content of disclosed information.

(7) Confidentiality
No information is to be leaked to a third party before an official disclosure is made.

3. Information Subject to Disclosure

This basic policy applies to the following information disclosure.

(1)Statutory Disclosure
①Disclosure in accordance with Financial Instruments and Exchange Act

• Disclosure of corporate information (securities reports, semi-annual reports, internal control reports and extraordinary reports, etc.)
• Disclosure of tender offer (tender offer notification and position statements, etc.)
• Disclosures related to ownership of a large volume of shares (large shareholding reports and holdings change reports, etc.)
• Disclosures based on Fair Disclosure Rule

②Disclosure in accordance with Companies Act (notices of ordinary General Meeting of Shareholders, financial statements, consolidated financial statements, business reports and supplementary schedules, etc.)

(2) Timely Disclosure
Disclosures in accordance with regulations of stock exchanges

• Decision Information (issuance of stock, acquisition of own stock, dividends, mergers, demergers, stock swap, business transfer, acquisitions, business alliances, takeover bids, etc.)
• Occurrence Information (loss or damage caused by disaster, filing of lawsuits or court decisions, bad debts, suspension of trade with business partners, etc.)
• Earnings Information (content of financial results, revision of earnings and dividends forecasts, etc.)
• Information on subsidiaries
• Information on corporate governance

(3) Voluntary Disclosure
Integrated Reports, Shareholders' Reports, Mid-Term Management Strategy, etc.

4. Disclosure Committee

The Company’s Disclosure Committee has been set up in order to construct, maintain and manage a proper information disclosure system. The committee is chaired by a Representative Director nominated by the President, and operates under the direct control of the President. The committee formulates general rules and basic policies for disclosure, constructs and adjusts the company structure concerning statutory disclosure and the timely disclosure, and also assesses the significance and validity of statutory disclosure and timely disclosure.

5. Other

(1) Dealing with Rumors in the Market
In principle, the Company does not comment on inquiries regarding rumors in the market.
However, if it is determined that there may be a significant impact on the Company caused by ignoring a specific rumor, appropriate action will be taken, such as issuing voluntary news releases.

(2) Handling of Information Related to Forecasts and Future Projections
In order to enable investors to make appropriate assessments of the Company’s business and future performance, information related to business result forecasts and other future projections will be accompanied by a forward-looking statements disclaimer to clearly indicate that the actual future results may differ.

Information Disclosure System Diagram

(1) Information Gathering Process
Officers responsible for information disclosure will make efforts to gather information. If any information requiring timely disclosure is grasped, the officer will report it to the Corporate Communications Department (department in charge of information disclosure).
The Corporate Communications Department reports all information requiring timely disclosure to the Corporate Accounting Department in charge of provisional financial reporting.

(2)Analysis and Decision Process
The necessity, to disclose information is discussed and confirmed with the relevant divisions and departments.
If necessary the matter is brought up for discussion by the Disclosure Committee.
Important matters are brought up for resolution by the Corporate Management Committee and/or Board of Directors.

(3)Disclosure Process
After obtaining approval by director of the Corporate Communications Department (and after being resolved by the Corporate Management Committee and/or the Board of Directors on important matters), information for timely disclosure is submitted to securities exchanges via TDNET. Statutory disclosures excluding disclosures based on Fair Disclosure Rules are provided via EDINET. The information that is disclosed in accordance with Fair Disclosure Rules is posted on the Company website.

IR & SR Policy

In keeping with the corporate creed of Fairness, Innovation, and Harmony, we strive to build relationships of trust with all stakeholders, including shareholders and investors, by providing information properly, fairly and in a timely manner, as well as in ways that are easy to understand. This information includes financial and business performance information as well as non-financial information needed to make investment decisions such as management strategy, in addition to the information that must be disclosed for statutory compliance. We aim to achieve sustainable growth in corporate value by obtaining remarks from stakeholders through an effective two-way dialogue, and sharing them within the Company including the management and directors.

IR & SR Policy

Fairness: Highly transparent IR & SR
Provide fair and clear disclosure of information based on the precepts of the Fair Disclosure Rules stipulated in the Financial Instruments and Exchange Act, as well as statutory and timely disclosures. Through this, we will fulfill our responsibility for accountability to all stakeholders while engaging in a sincere dialogue.

Innovation: Progressive and Creative IR & SR
The management, including the President, CFO and directors, will actively participate in various IR events to increase the opportunities for dialogue with shareholders and investors. For the planning and operation of IR events, and the creation of publications and IR website content, we keep ourselves innovative in making the content easy to understand for participants/viewers, while maintaining a broad perspective.

Harmony: IR & SR through two-way dialogues
The opinions and requests obtained through dialogue with shareholders and investors, mainly by the President, CFO and department responsible for IR & SR, will be collected and shared as feedback within the Company including the management and directors. The department responsible for IR & SR will lead the organic coordination within the Company through timely sharing of information among relevant departments.

Quiet Period

A quiet period of three weeks prior to the announcement of financial results for quarters and full year is observed in order to prevent leak of financial information. During this period, representatives of the Company will refrain from answering questions or making comments related to the financial results or performance forecasts. However, this quiet period does not apply to other information including statutory and timely disclosures.