1．Basic Policy
Skyfall Inc. (the “Company”) is committed to providing shareholders, investors, and other stakeholders with timely and accurate information in a transparent, fair, and consistent manner. Through such disclosure, the Company strives to earn and maintain the trust and understanding of its stakeholders.
2．Disclosure Standards
The Company discloses material information concerning the Company in accordance with the Financial Instruments and Exchange Act and other applicable laws and regulations, as well as the timely disclosure rules of the Tokyo Stock Exchange (the “Timely Disclosure Rules”).
Even when information is not subject to disclosure under applicable laws and regulations or the Timely Disclosure Rules, the Company endeavors to disclose information fairly and proactively when it determines that such information would be useful in enhancing stakeholders’ understanding of the Company.
However, personal information, confidential information concerning business partners and other parties, and other information subject to confidentiality obligations will not be disclosed unless disclosure is required by applicable laws and regulations.
3．Methods of Disclosure
The Company discloses information required under the Timely Disclosure Rules through the Timely Disclosure Network (TDnet) operated by the Tokyo Stock Exchange. Following disclosure through TDnet, the same information is also promptly posted on the Company’s website.
Information that is not subject to disclosure under applicable laws and regulations or the Timely Disclosure Rules, but that the Company considers useful to shareholders and investors, will also be disclosed fairly through the Company’s website, press releases, or other appropriate means.
The Company also complies with the Fair Disclosure Rule under the Financial Instruments and Exchange Act. When handling material information subject to the Fair Disclosure Rule, the Company will disclose such information in accordance with applicable laws and regulations. If any disclosed information requires correction, the Company will promptly take appropriate action in accordance with applicable laws and regulations.
4．Prevention of Insider Trading
To appropriately manage undisclosed material information and prevent insider trading, the Company has established and strictly enforces internal rules concerning the management of internal information and the prevention of insider trading.
The Company also provides its directors, officers, and employees with training and ongoing education regarding insider trading regulations and the appropriate handling of material information to ensure compliance with applicable laws, regulations, and internal rules.
5．Handling of Earnings Forecasts and Forward-Looking Information
Among the information disclosed by the Company, statements that are not historical facts, including earnings forecasts and future business outlooks, are based on information available at the time of disclosure and certain assumptions deemed reasonable by the Company.
Actual results and performance may differ from these forecasts due to economic conditions, market trends, and various other factors.
If any material revision to such information becomes necessary, the Company will disclose the revised information in a timely and appropriate manner in accordance with applicable laws and regulations and the Timely Disclosure Rules.
6．Quiet Period
To prevent the leakage of financial results, including quarterly financial results, and to ensure fairness in information disclosure, the Company designates the period from the day following the end of each fiscal quarter, including the fiscal year-end, until the date of the relevant financial results announcement as a “quiet period.”
During this period, the Company refrains from commenting on or responding to inquiries regarding financial results or earnings forecasts.
However, if a material revision to an earnings forecast becomes necessary or a matter subject to timely disclosure arises during the quiet period, the Company will disclose such information in a timely and appropriate manner in accordance with applicable laws and regulations and the Timely Disclosure Rules.
7． Internal Disclosure Framework
In accordance with this Policy, the Company establishes and maintains a framework for the collection and management of information and the determination of disclosure matters, led by the Information Handling Officer, in order to ensure the continued timely and appropriate disclosure of information in compliance with applicable laws and regulations and the Timely Disclosure Rules.
The Company also strives to strengthen its internal disclosure framework by continuously reviewing its internal rules and operational systems for the management of internal information and by providing regular training and education to its directors, officers, and employees.
