Disclosure Policy

With respect to disclosing corporate information, Startia complies with the Financial Instruments and Exchange Act, the Tokyo Stock Exchange’s rules on timely disclosure, and our own Regulations on Insider Information. Information related to important decisions and important occurrences in the company, as well as information about financial results are examined by the President, Representative Director and the Internal Information Management Officer (Corporate Executive Officer/Administration Department General Manager) to determine whether or not they constitute facts stipulated in the Tokyo Stock Exchange’s rules on timely disclosure, and if so, while receiving advice from the Legal Department and the Finance Department, and checking with the Tokyo Stock Exchange, our legal counsel and consultants, etc., we announce such information while making sufficiently sure to prevent any insider trading.

1. Basic Principles for Corporate Information Disclosure

1. Basic Principles

  • ・Timely information disclosure
  • ・Lawful and appropriate information disclosure
  • ・Fair information disclosure
  • ・Voluntary information disclosure
  • ・Continuous information disclosure

2. Objectives and Basic Principles of our IR Activities

Startia’s IR activities seek to enable shareholders and other investors to gain a better understanding of the company.Our basic stance is to always look at things from the viewpoint of shareholders and other investors, and to provide the most recent information quickly, accurately and fairly.
The materials we release, the contents of our website, and other information sometimes includes the company’s current plans and outlooks, as well strategies. Information that is not historical fact constitutes future outlooks prepared based on certain assumptions, and is based on the decisions of Startia’s senior management team using information available at the time the outlooks are made.In addition, Startia does not support any forecasts for our financial results made by third parties.

3. Information Disclosure Methods

With respect to information disclosure, the Corporate Executive Officer/Administration Department General Manager acts as the Internal Information Management Officer, and information is disclosed in compliance with both the Financial Instruments and Exchange Act as well as the Tokyo Stock Exchange’s rules on timely disclosure.

4. Self-Imposed Control Periods (Quiet Periods)

From the next day of the last day of Startia’s quarterly fiscal periods (ending in March, June, September, and December) until the announcement of our operating results are “IR quiet periods, “During these periods, Startia does not engage in any IR activities as a self-imposed policy. During these periods, the company refrains from commenting on, or answering any questions about financial results
However, in the event that the company determines that the future outlook may differ greatly, the company will disclose such information, which may include revisions and changes at the company’s discretion.

5. Investment Solicitation Denial

Information that the company releases and/or posts on the website is not intended to solicit investment. Investors are asked to make investment decisions on their own.

2. Overview of Information System

1. Information Officer and Department Responsible for Information Disclosure

Collaborating with the President, Representative Director, the department responsible for information disclosure (Corporate Planning Office) and the corporate auditors, the Internal Information Management Officer (Corporate Executive Officer/Administration Department General Manager) is in charge of disclosure, including timely disclosure, and IR activities.

2. Use of Outside Experts

Any questions about timely disclosure are quickly directed to outside experts serving as advisors to the company, including attorneys, consultants and other professionals with expertise in disclosure.

3. Disclosure Methods

Important information is first disclosed on the Tokyo Stock Exchange’s TDnet System. After registering the information on the TDnet System, we quickly post the same materials on the company’s website.

3. Analysis of the Disclosure of Information

1. Decisions

1. Information Collection and Analysis Methods

With respect to important decisions made at the Shareholders’ Meeting, Board of Directors Meetings, or other meetings, the Internal Information Management Officer (Corporate Executive Officer/Administration Department General Manager), in collaboration with the President, Representative Director, makes sure that such information is not leaked from the stage that decisions are being planned, and works with the Corporate Planning Office to prepare necessary disclosure documents and other materials, and to be ready to respond to any disclosure event in a timely manner.
When it is difficult to determine whether or not disclosure is necessary, the company consults with the Tokyo Stock Exchange, legal counsel, consultants, and other relevant parties, thereby striving to ensure timely disclosure of information.

2. Decision Making Body

Board of Directors

3. Internal Checking Body

Internal Information Management Officer (Corporate Executive Officer/Administration Department General Manager), Corporate Planning Office, Administration Department

2. Incidence

1. Information Collection and Analysis Methods

At the point in time when the company’s employees become aware that an event has occurred, the President, Representative Officer, as well as the Internal Information Management Officer (Corporate Executive Officer/Administration Department General Manager) ask the General Manager supervising the event in question to report the information. The necessary information for disclosure is then immediately compiled and disclosed at the right time.

2. Decision Making Body

Board of Directors

3. Corporate Planning Office,Administration Department

Administration Department

3. Operating Results

1. Information Collection and Analysis Methods

If a Board of Directors meeting is held with respect to full fiscal year or quarterly financial results, we will release information through full-year financial results or quarterly financial results prepared in advance by the Administration Department.

2. Decision Making Body

Board of Directors

3. Internal Checking Body

Administration Department