Disclosure Policy

Aim of IR activities and basic stance

The aim of investor relations (IR) activities at NID is to provide shareholders, investors and analysts with the necessary information to assess the Company’s value fairly.

To this end, we believe in undertaking IR activities with complete sincerity at all times. Our basic stance is to disclose information about NID’s management policies, business strategy, financial status and other matters as accurately and fairly as possible, and in a manner that is both timely and easy to understand.

Internal application of disclosure policy

NID is committed to ensuring that this disclosure policy applies equally to the parent Company and to the entire NID Group. The IR Division is the only part of the Company authorized to deal with inquiries received from investors and shareholders. The purpose of this rule is to protect NID and its employees from exposure to liability under the Securities and Exchange Law or other Japanese legislation.

Disclosure standards

NID’s disclosure is in accordance with the Securities and Exchange Law and with the rules stipulated by the JASDAQ Securities Exchange concerning the timely disclosure of corporate information by issuers of listed marketable securities (hereafter “disclosure rules”). Regarding any information to which the disclosure rules are not applicable, NID’s policy is to provide full and fair disclosure by an appropriate method of any information that the Company judges would serve to enhance the understanding of all investors.

Disclosure methods

Disclosure of any information to which the disclosure rules are applicable shall, in accordance with these rules, be undertaken through its publication on the system provided by the Tokyo Stock Exchange for timely disclosure of information on listed companies (TDnet), having first provided the JASDAQ Securities Exchange with relevant explanation. NID shall also publish all information disclosed via TDnet on its corporate web site without delay. In instances where the disclosure of this information requires the preparation of PDF files or other communication tools, there may be a significant delay between the publication of the information on the NID web site and its release via TDnet. Moreover, even in the case of information to which the disclosure rules are not applicable, in consideration of the purpose of timely disclosure, NID undertakes to make all necessary efforts to ensure that such information is released to the general investor community by an appropriate method as accurately and fairly as possible. Accordingly, investors wishing to confirm any disclosed information about NID are kindly asked to refer to the Company’s web site as well as checking TDnet and other sources.

Performance forecasts and other projections

For the convenience of investors, NID shall endeavor to disclose detailed information on the Company’s financial performance on a quarterly basis (including interim and full-year data). As well as striving to improve as far as possible the accuracy of its performance forecasts and other future projections, NID shall disclose without delay any changes in these forecasts as they occur. However, since such forecasts are necessarily predicated on assumptions and judgments made by NID based on the best information available at that time, the Company makes no guarantee as to the content of such predictions.

NID shall not make any reference or allusion whatsoever to any performance forecast made by any analyst, publication or other third party, in view of the fact that such forecasts represent the opinions of the persons making such forecasts.

Non-disclosure periods

To prevent divulgence of any results-related accounting information or other data that could affect the Company’s share price, NID shall not undertake material disclosure during those intervals lasting from the day following the end of an accounting period to the day on which the results for that period are announced. During these non-disclosure periods, the Company shall refrain from making any comments to specific shareholders and investors or to the mass media concerning any accounting details, results, earnings forecasts or other predictions. NID shall also refrain from giving any presentations or holding any meetings for the benefit of analysts or individual shareholders and investors during such periods. However, in the event that any performance forecasts should come to differ significantly from published earnings forecasts during the non-disclosure period, the Company shall disclose this information at an appropriate time. Please refer to the IR calendar section of the NID web site for details of results announcement dates.