Disclosure Policy

1. Standards for Information Disclosure

In accordance with the Financial Instruments and Exchange Act and other laws and regulations, as well as the “Rules Concerning the Timely Disclosure of Corporate Information” (hereinafter, the “Timely Disclosure Regulations”) set forth in the Tokyo Stock Exchange’s Securities Listing Regulations, the company discloses information promptly on the basis of transparency, fairness, and continuity. Even where various laws and regulations and the Timely Disclosure Regulations do not apply, the company proactively and publicly discloses information that it judges to be important or beneficial in helping shareholders and investors understand the company.

We do not disclose personal information, customer information, or information that would infringe upon the rights of related parties.

2. Information Disclosure Methods

We disclose information stipulated by the Timely Disclosure Regulations as indicated by these regulations via the timely disclosure information distribution system provided by the Tokyo Stock Exchange (TDnet). We also post such information on our own website promptly after publishing it on TDnet. Information that we judge to be important or beneficial but to which the Timely Disclosure Regulations do not apply is disclosed broadly, including by posting on our company website.

3. Prevention of Insider Trading

We have formulated the Information Management Regulations and the Insider Trading Management Regulations to prevent insider trading. We also hold study sessions on insider trading regulations each year for executives and employees and distribute a practical guide to ensure a thorough understanding and awareness of the essence of these regulations. In addition, we send out internal notifications about insider trading, as appropriate.

4. Handling of Earnings Forecasts and Other Forward-Looking Information

Information the company discloses that pertains to earnings forecasts, future projections, strategies, targets, and other items that are not past or current facts are forward-looking statements. These statements represent plans, expectations, and judgments the company deems rational based on the information currently available. Accordingly, actual business results may differ from the indicated forecasts due to changes in economic circumstances and other uncertainties.

5. Quiet Period

To prevent leaks in information about operating performance (including information on quarterly earnings), as well as to ensure the fair disclosure of information, we have set aside the period from the day following the end of the fiscal year (or quarter) to the date when those results are announced as a quiet period. During that period, we refrain from responding to questions about or commenting on operating performance or results forecasts. However, if expectations of significant changes in forecasts of operating results arise during that period, we announce such information as appropriate, in accordance with the Timely Disclosure Regulations.

6. Internal Structure

In accordance with this disclosure policy, we have put in place and are endeavoring to enhance our internal systems for disclosing information as appropriate under various laws and regulations and the Timely Disclosure Regulations.

7.Confimarion Letter to Comply with Rules in Exchange Market

SHIFT has submitted “Confirmation Letter to Comply with Rules in Exchange Market” to Tokyo Stock Exchange.