VELTRA VELTRA

Disclosure Policy

1.Criteria for Information Disclosure

VELTRA Corporation and its consolidated subsidiaries (hereinafter the "VELTRA Group") disclose information in accordance with the Financial Instruments and Exchange Act, other relevant laws and regulations, Rules Concerning Timely Disclosure of Corporate Information by Issuers of Listed Securities set by the Tokyo Stock Exchange (hereinafter the "TSE") and the like (hereinafter "Timely Disclosure Rules"). The VELTRA Group discloses information in accordance with Timely Disclosure Rules in cases where any information, decision or occurrence related to account settlement that may affect investment decisions arose. Moreover, the VELTRA Group adopts the basic policy of disclosing information outside the scope of Timely Disclosure Rules judged to be useful for investors' understanding of itself as proactively and fairly as possible using appropriate means.

2.Information Disclosure Method

The VELTRA Group discloses information under the scope of Timely Disclosure Rules using the Timely Disclosure Network (TDnet) offered by the TSE. In principle, the VELTRA Group promptly publishes the disclosed information at the IR website for the Group as well. The VELTRA Group tries to disclose information stated in the Basic Policy but left outside the scope of Timely Disclosure Rules as proactively and fairly as possible, too, taking the objective of the Timely Disclosure Rules into consideration.

3.Prevention of Insider Trading

The VELTRA Group has established internal regulations in order to prevent insider trading. The VELTRA Group is working to make those regulations known to all Group directors and employees and further their understanding and awareness. Moreover, the VELTRA Group acts to prevent insider trading through the appropriate management of information about important facts that may affect investment decisions and speedy information disclosure in accordance with Timely Disclosure Rules.

4.How Results Forecasts and Future Information Are Handled

Results forecasts, future outlooks, strategies, targets and the like disclosed by the VELTRA Group other than those related to past or present facts are descriptions about future outlooks. They are based on information the VELTRA Group had at the point of their disclosure and plans, expectations and assessments based on certain assumptions that are judged to be rational. Consequently, various uncertain and variable factors, such as risk factors and economic conditions, may cause actual results to differ from disclosed forecasts. Please be aware of this possibility.

5.Quiet Periods

The VELTRA Group sets periods from the day after the last day of each settlement term (quarterly settlement terms) to the day of announcing the respective financial results as quiet periods in order to prevent the leakage of account settlement information (including quarterly account settlement information) and to guarantee the fairness of information disclosure. During quiet periods, the VELTRA Group refrains from answering questions about account settlement and results forecasts, disseminating related information and providing other comments. The VELTRA Group, however, discloses information about facts judged as greatly influencing investment decisions during quiet periods in accordance with Timely Disclosure Rules as the occasion demands as an exceptional measure.

6.Preparation of Internal Systems

Based on this Disclosure Policy, the VELTRA Group is preparing and refining its internal systems in a bid to disclose information appropriately in accordance with various laws, regulations and Timely Disclosure Rules.