Disclosure Policy

The Cosmo Energy Group Management Vision is, "In striving for harmony and symbiosis between our planet, man and society, the Cosmo Energy Group aims for sustainable growth towards a future of limitless possibilities." True to our Vision, we are determined to earn the trust of stakeholders consistently, and we make it our basic policy to disclose important management-related information such as financial performance in a timely and appropriate manner and to proactively share non-financial information, as well. Moreover, as articulated in the Cosmo Energy Group Code of Conduct, we value communication with society and proactively engage in constructive dialogue with shareholders, investors, and other external stakeholders in order to continually enhance corporate value. This Disclosure Policy is based on our Management Vision and Code of Conduct and outlines our approach to information disclosure.

1. Information disclosure standards

We comply with Japan's Companies Act, Financial Instruments and Exchange Act (including the Fair Disclosure Rules), and other laws and regulations, as well as the Rules on Timely Disclosure of Corporate Information by Issuers of Listed Securities (Timely Disclosure Rules) stipulated by the Tokyo Stock Exchange (TSE). Whenever it is determined that certain information would promote greater transparency for stakeholders, we also proactively share that information, even if it is not mandatory to disclose under applicable laws and regulations or the Timely Disclosure Rules.

2. Information disclosure method

Immediately after required information is disclosed via the Timely Disclosure Network (TDnet) operated by the TSE, we also post it on the Group's public website. We also publicly share additional important information not subject to disclosure under the Timely Disclosure Rules on our website.

3. Prevention of insider trading

We maintain internal rules to manage important company information properly and prevent insider trading. We take thorough steps to raise the awareness of all Group employees to ensure that these rules are fully understood and followed.

4. Handling of business forecasts and forward-looking information

When we disclose our plans, outlooks, management goals and the like, we base any information which is historical fact on our best determinations and assumptions, using the information available at the time of writing. Actual business results may differ significantly from outlooks and forward-looking statements due to various factors. Factors that affect business performance can include, but are not limited to, economic conditions, crude oil prices, supply and demand trends for petroleum products, market conditions and exchange rates.

5. Quiet period (for managing information disclosure)

In order to prevent premature leaks of important company information and ensure fair access to information, we have established a "quiet period" from the day after the end of each quarter to the official announcement of financial results (about one month). During this period, we refrain from making comments on or answering inquiries related to our financial results. However, we still respond to inquiries regarding information that has already been published, even during a quiet period. Nevertheless, if anything occurs during this period that is subject to the Timely Disclosure Rules, we share the relevant information in a timely and appropriate manner.

6. Internal disclosure system

Whenever it is deemed necessary, based on an examination by our Legal and General Affairs Department, to disclose a decision or factual occurrence under the Timely Disclosure Rules, we make a timely disclosure to the Tokyo Stock Exchange after reporting the matter to the Board of Directors and the Executive Officers' Committee. Even information that is not required to be disclosed under the Timely Disclosure Rules is publicly released by the Corporate Communication Department on our website or via the mass media, based on this policy.

With regard to ESG information, the Sustainability Strategy Committee, which is chaired by the President and CEO and deliberates on non-financial policies and indicators, examines and determines Group ESG information to be disclosed based on a variety of perspectives.