Disclosure Policy

Basic Approach

Heiwa Real Estate strives to disclose important information about the Company in an impartial, timely, and proper manner so that its shareholders, investors, and other stakeholders have a sound basis for understanding and accurately evaluating its activities and performance.

1. Standards of Information Disclosure

Heiwa Real Estate will promptly disclose information based on the principles of transparency, impartiality, and continuity in accordance with relevant laws, such as the Financial Instruments and Exchange Act, and timely disclosure rules set by the Tokyo Stock Exchange. The Company will also proactively disclose information that is not subject to such laws and rules to the extent possible if such information is deemed useful for shareholders and investors.

2. Methods of Information Disclosure

Heiwa Real Estate will disclose information on matters subject to the timely disclosure rules set by the Tokyo Stock Exchange through the Timely Disclosure Network (TDnet) provided by the exchange and in accordance with the same rules. It also makes its securities reports available through the Electronic Disclosure for Investors Network (EDINET) overseen by the Financial Services Agency of Japan. If information not subject to such rules is deemed to be pertinent for investment decisions, the Company will disclose it through suitable and relevant means depending on the degree of importance and urgency of the information.

3. Preventative Measures against Insider Trading

Heiwa Real Estate has established in-house rules for properly managing important Company information in order to prevent cases of insider trading, and, accordingly, strictly controls insider information during communications with shareholders and investors.

4. Fair Information Disclosure

Heiwa Real Estate adheres to fair disclosure rules and strives to promptly and impartially disclose information in an appropriate manner when fulfilling its obligation to announce important information in accordance with relevant laws and regulations.

5. Quiet Period

Heiwa Real Estate sets a quiet period from the day following the closing date of each fiscal quarter until the release of the respective quarterly financial report in order to prevent any leakage of results and ensure the impartiality of its financial reporting. During the quiet period, all members of the Company are prohibited from commenting on or responding to questions about the financial results. In the event a substantial difference between the Company’s latest earnings forecast and results is apparent during the quiet period and subject to timely disclosure rules, the Company will disclose the relevant details in a compliant and appropriate manner.

6. Policy for Clarifying Ambiguous Information

In the event that ambiguous information about Heiwa Real Estate has been disseminated and the subject matter is deemed as important for investment decisions by shareholders and investors, or the Tokyo Stock Exchange has enquired about such information, the Company will clarify the matter in an appropriate and responsible manner in accordance with relevant standards and methods that have been determined.