Disclosure Policy

　The basic policy for information disclosure by DIGITAL HOLDINGS, INC. (“the Company”) is that information about the Company shall be disclosed to shareholders, investors, and other stakeholders in a fair, timely, and appropriate manner.
　The Company also aims to improve management transparency and maximize corporate value through communications with shareholders and investors.

　The Company shall disclose/release information in accordance with the related laws and regulations, including Companies Act and the Financial Instruments and Exchange Act, or with the rules set by financial markets with which the Company is obliged to comply (“Timely Disclosure Rules”). The Company shall also strive to proactively disclose/release information not covered by these laws and regulations as well as rules (“Voluntarily Disclosed Information”) that is considered to be helpful to an understanding of the Company’s situation.

• * In the event of a successful application for the new listing on the stock exchange of shares held by the Company (including investments held by funds operated by the Company), a voluntary disclosure shall be made promptly after approval is made public, if such a disclosure is necessary. If the sale of shares at the time of such a stock exchange listing means that a revision to the Company results forecast is likely, a decision shall be made promptly once the public offering or sale price is determined and a timely disclosure or voluntary disclosure will be made if deemed necessary.
• * Presentation material and other documents are available at financial results briefings regarding the actual information released in the case of Voluntarily Disclosed Information. The Company also takes active steps to provide overseas investors with the information they need to make investment decisions, with financial results being provided in English translation.

　Information disclosed on the basis of the related laws and regulations or Timely Disclosure Rules (“Laws and Regulations/Timely Disclosed Information) shall be posted on the Company web site promptly after its disclosure/release on EDINET (the electronic corporate disclosure system for the publication of financial statements and other documents under the Financial Instruments and Exchange Act) or the Timely Disclosure network (TDnet) of the Tokyo Stock Exchange pursuant to the said related laws and regulations or Timely Disclosure Rules. Voluntarily Disclosed Information shall be posted on TDnet or the Company web site.
　While the disclosure of “important information” will be done in a fair manner, in the event that “important information” is communicated unintentionally, such information will be released promptly on TDnet or the IR section of the Company web site in accordance with the fair disclosure rule (Article 27-36 of the Financial Instruments and Exchange Act).

　The Company shall formulate “rules regulating the disclosure of group information” to stipulate the procedures and other practices regarding the collection, preparation, and disclosure of “Laws and Regulations/Timely Disclosed Information and Voluntarily Disclosed Information. When such disclosure/release are required, the relevant departments, subsidiaries, and affiliates shall work together to prepare the documents for disclosure and these shall be disclosed subject to decision by the board of directors or the director responsible for disclosure.

　To ensure that information disclosure is conducted fairly and to put rigorous measures in place to prevent the leaking of information prior to disclosure/release, the Company shall designate the time from the day following the end of the accounting period until the publication of financial results as a “quiet period”. During this period, the Company will not make any comments on or answer questions regarding the financial results.
　However, the Company will continue to respond to questions during this period that relate to information that has already been disclosed/released or is public knowledge.

　Information disclosed by the Company is for the purpose of dissemination of general information about the DIGITAL HOLDINGS group and not for the purpose of promoting investment in shares or other financial instruments issued by the Company.
　Any included information about industry, market trends, or economic conditions is based on information available at the time of disclosure/release and the Company offers no guarantees regarding the validity, accuracy, reasonableness, or comprehensiveness of the information.
　Furthermore, any information about the DIGITAL HOLDINGS group’s plans, estimates, forecasts, expectations, or other information about the future represents nothing more than the Company’s judgments or thinking at the time of disclosure/release, and the financial performance, financial situation, and other results of the DIGITAL HOLDINGS group may, due to factors such as economic conditions and market trends, differ significantly from this disclosed information and from predictions that might be made on the basis of this disclosed information.

　The Company web site includes an IR section that is provided to improve understanding of and trust in the Company by its shareholders, investors, and other stakeholders, to present the attractiveness of the Company as an investment in an easily understood form, and to publish IR information in a timely and fair manner in terms of fair disclosure.
　While Laws and Regulations/Timely Disclosed Information will be posted on the Company web site promptly after the disclosure/release on the basis of the related laws and regulations or Timely Disclosure Rules, please note that delays in posting may occur due to problems such as faults in information and communications technology.