DISCLOSURE POLICY

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Basic Policy

Japan Investment Adviser Co., Ltd. (hereinafter referred to as "the Company") shall, based on the principles set forth in the Compliance Manual, communicate with all stakeholders (hereinafter referred to as "stakeholders"), including shareholders, investors, customers, business partners, and local communities. The Company will actively disseminate corporate information, including management strategies and financial conditions, in a timely, fair, accurate, and continuous manner. By doing so, we aim to increase the transparency of our management and to gain the trust and appropriate evaluation of our stakeholders.

Standards for Timely Disclosure

The Company shall disclose material information, such as decisions, occurrences, and financial results that may affect the investment decisions of stakeholders, in accordance with the Financial Instruments and Exchange Law and other relevant laws and regulations, and the Timely Disclosure Rules, etc., established by the Tokyo Stock Exchange (hereinafter referred to as the "Timely Disclosure Rules"). In addition, even if the information does not fall under the criteria set forth in the Timely Disclosure Rules, we will strive to proactively disclose information that is useful to our stakeholders, while referring to the opinions of the Finance Bureau and the Tokyo Stock Exchange.

Internal System for Timely Disclosure

The PP & IR Group of the Company (hereinafter referred to as the "Department in Charge of Timely Disclosure") shall be the department in charge of Timely disclosure, and shall supervise Timely disclosure operations in accordance with the Timely Disclosure Rules, as well as liaison operations with the Tokyo Stock Exchange. The department in charge of Timely Disclosure strives to inform internal departments of the importance of Timely disclosure, and internal departments report to and consult with the department in charge of Timely disclosure regarding decisions and facts that arise in the course of business activities that are considered to have a significant impact on investors' investment decisions. Such important information is collected from other departments in the Administration Division to the department in charge of Timely Disclosure through internal reporting or the process of approval by the prescribed resolution.
Important matters such as decisions, occurrences, and financial information of subsidiaries are also required to be approved or reported as prescribed by the Company, and important or potentially important corporate information within the Group is collected from each department within the Company to the department in charge of Timely Disclosure without omission or delay through the process of internal reporting by subsidiaries to the department in charge of the relevant subsidiary or approval by the Company.

Method of Timely Disclosure

Disclosure of information falling under the Timely Disclosure Rules shall be made through the "Timely Disclosure Network" (TDnet) provided by the Tokyo Stock Exchange in accordance with the said rules. Disclosure documents such as annual securities reports and quarterly reports are published through the Electronic Disclosure for Investors' NETwork (EDINET) provided by the Financial Services Agency.
In order to provide investors with a fair means of access to timely disclosure, information is promptly posted on the Company's website after it is made available through the TDnet and the EDINET.
In addition, when voluntarily disclosing information that does not fall under the scope of disclosure items under the Timely Disclosure Rules, we make sure that the information is communicated to our stakeholders in accordance with the purpose of timely disclosure, while referring to the opinions of the Financial Bureau and the Tokyo Stock Exchange.

Response to the spread of rumors

It is the Company's basic policy not to comment on market rumors or newspaper reports about the Company. However, if it is determined that there could be a significant impact on capital market participants or the Company, or if there is an inquiry from a stock exchange, etc., the Company shall take appropriate action to clarify the truth of the rumor or report.
In cases where the business activities between the Company and a third party may fall under the category of important information, the Company shall make an agreement with the other party in advance to disclose such information with the prior consent of the Company.

Setting of Quiet Period

In order to ensure fair and timely disclosure from the perspective of fair disclosure, the Company shall set the period from the day following the date of the quarterly settlement of accounts to the date of the announcement of the settlement of accounts as a silent period, during which the Company shall refrain from responding to any comments or questions related to the settlement of accounts. However, if, during the quiet period, there is a prospect of a significant change from the earnings forecast, we will make an announcement in accordance with the Standards for Timely Disclosure. During the silent period, we will continue to respond to questions regarding information that has already been made public.

Function as a check for risks of inappropriate timely disclosure

The General Affairs Department, which is in charge of information management, and the Department in Charge of Timely Disclosure share the relevant information to prevent "omissions in timely disclosure due to lack of awareness", "disclosure of unapproved matters", and "delays in disclosure of crisis matters that occur unexpectedly". We will build a management system that ensures timely disclosure without omissions by having both departments act as checks and balances.

Disclaimer

Among the disclosed information, statements regarding business forecasts and future projections are based on judgments made in accordance with information available at the time, and include potential risks and uncertainties. Accordingly, actual results may differ from these forecasts due to a variety of factors.
The disclosed information is intended to deepen your understanding of our company and is not intended as a solicitation for investment. Investors are requested to make investment decisions at their own discretion.

Establishment of internal rules for timely disclosure, etc.

The Company will strive to develop and enhance internal systems, such as rules and manuals, so that the above information can be disclosed appropriately. In addition, the Company will actively promote the further development of a system for Timely Disclosure and IR promotion.