（１）Basic Disclosure Policy
Kudan Inc. (hereafter “the Company”) proactively discloses information that could be deemed important and beneficial for shareholders and investors to promote better understanding of the Company in a fair and timely manner in accordance with rules on relevant laws and regulations including the Financial Instruments and Exchange Act, and timely disclosure rules established by the Tokyo Stock Exchange (hereafter “Timely Disclosure Rule”).
In addition, the Company does not provide personal information, customer information and information that may violate the rights of others.
The Company strives to quickly disclose information in accorance with Timely Disclosure Rule via the Timely Disclosure Network (TDnet) operated by the Tokyo Stock Exchange, and publish such disclosure materials as securities reports and quarterly reports in a prompt manner via Electronic Disclosure for Invesotrs’ NETwork (EDINET) operated by the Financial Services Agency.
In addition, even though certain information is not required to be disclosed under Timely Disclosure Rule, the Company plans to make appropriate, accurate and fair dislosures of the information that could be considered important and valuable to be disclosed.
（３）Prevention of Insider Trading
The Company has formulated the Information Management Regulations and the Insider Trading Management Regulations to prevent insider trading. In addition, the Company hold study sessions about insider trading regulations every year for executives and employees, and distribute a practical guidebook to ensure a thorough understanding and awareness of the essence of the regulations. Moreover, the Company appropriately sends out internal notifications regarding insider trading.
（４）Cautionary Note Concerning Business Performance Forecasts and Forward‐Looking Statements
The statements with respect to the Company’s business perfromance forecasts, future prospects, strategies and goals that do not come from historic and current facts are forward-looking statements. Such statements are reflected by plans, expectations and management judgements that are based on information available and deemed reasonable at the time of publication and therefore by no means guarantee the Company’s future business performance. Due to a number of certain risks and uncertainities, the Company’s actual business performance may differ from forecasts and any related predictions presented.
To prevent leakage of financial results including quarterly reports and ensure fairness in the disclosure of information, the Company observes a “Quiet Period” that starts from the day following the end of a fiscal quarter to the day of the announcement of financial results for that fiscal quarter. During this period, the Company refrains from making any comments or responding to any inquiries about its financial results and business forecasts . Exceptions may be made, however, when business forecasts may be changed significantly during this period or when there is occurrence of material events that could have a considerable impact on investment decisions of investors.
To act in accordance with this Disclosure Policy, the Company strives to improve and enhance its internal structure in order to make appropriate disclosure of information in compliance with Timely Disclosure Rule, relavant laws and regulations.