Information Disclosure Policy

SBI Holdings’ basic policy on information disclosure is to fulfill its responsibilities as a listed company by disclosing important matters to all of its customers, shareholders, investors, community and other stakeholders in a timely, appropriate, and fair manner, while engaging in increasing corporate value by ensuring management transparency and fairness.

Furthermore, opinions and concerns expressed by stakeholders to the Company through its information disclosure program are informed to the management and relevant business units as appropriate, among other information sharing and utilization activities, which we leverage to raise its corporate value in a sustained manner.

SBI Holdings discloses information in conformity to relevant laws and ordinances, such as the Companies Act and the Financial Instruments and Exchange Act, as well as to timely disclosure-related regulations prescribed by stock exchanges on which the Company lists its securities.

SBI Holdings will proactively disclose information, which the Company considers helpful for shareholders and investors to better understand its corporate activities and business strategies, and are deemed to be material for their investment decision-making, even if the information is not among types of information required to be disclosed pursuant to relevant laws and ordinances and timely disclosure-related regulations.

SBI Holdings defines the term “Information Applicable to Disclosure” as follows. Moreover, SBI Holdings will proactively disclose corporate information considered useful for helping the SBI Group to be better understood.

▽　Timely disclosure
Pursuant to relevant laws and ordinances and stock exchange regulations, SBI Holdings discloses information via the Electronic Disclosure for Investors’ NETwork (EDINET), an electronic disclosure system for Securities Reports, provided by the Financial Services Agency (FSA) under the Financial Instruments and Exchange Act, or via the Timely Disclosure network (TDnet), a timely disclosure information dissemination system, made available by a stock exchange. Information disclosed via the EDINET or the TDnet will be promptly presented on the Company’s website.

▽ Disclosure of Information Subject to Arbitrary
Through initiatives such as holding multiple briefings for market-related entities, media, shareholders and individual investors, SBI Holdings endeavors to be accurately recognized and determined of its management. Furthermore, SBI Holdings will continuously strive to build a highly transparent management by issuing publications, including Annual Reports and Business Reports, as well as distributing news releases, delivering information in a timely manner that proactively utilizes various web-based tools, such as online video streaming and upload of presentation materials.

Also, SBI Holdings is positively making efforts on disclosing information in English, in order to fairly provide disclosure to more stakeholders whether domestic or abroad.

SBI Holdings has designated the Director in charge of finance and accounting, as the person responsible for handling information for timely disclosure, and has established the Corporate Communications Dept. as the business unit in charge of practical services for information disclosure.
In close collaboration with relevant business units such as the Accounting, Finance, General Affairs, and Legal & Compliance Departments, as well as external experts (lawyers and accountants, among others), the person responsible for handling information and the Corporate Communications Dept. will exhaustively gather information targeted for disclosure (decisions, events, and information on subsidiaries), promptly disclosing the information when appropriate and in consideration of fairness for market-related entities.

For financial closing information, with the General Manager of the Accounting Dept. serving as the manager in charge for creating disclosure documents, the Accounting Dept. and relevant business units will create documents, based on information gathered from the SBI Group companies, and disclose the information promptly.

Pursuant to Insider Trading Control Regulations stipulating matters required to be observed concerning proper control of internal information and trading of shares and so on, SBI Holdings will rigorously ensure that internal information is thoroughly controlled and insider trading is prevented from being committed by directors and employees.

To prevent the leakage of unannounced financial results information during the results announcement preparation period and ensure the fairness of investor relations activities, SBI Holdings observes a quiet period from the day after each quarterly closing until the day of the financial results announcement. During this period, SBI Holdings refrains from responding to financial results inquiries and withholds from holding individual IR meetings.

SBI Holdings discloses material information that could influence investment decision-making in a fair and impartial manner in its interactions with investors and analysts. And when engaging in dialogues, SBI Holdings will only mention facts that have already been disclosed, generally known facts, or other information on such topics as the general business environment.

Moreover, SBI Holdings is not in a position to comment on different types of information communicated by third parties, such as company ratings and results forecasts. However, if the Company regards the said information to involve a factual error or guessing-based false information that is feared to seriously affect investors’ investment decision-making, it would potentially point out the factual error and the like.

Information disclosed by SBI Holdings may include future forecasts and strategies that are not historical facts but are based on conclusions and assumptions the Company judged to be reasonable given the information available at the time. SBI Holdings does not guarantee the appropriateness and accuracy of such conclusions and assumptions. SBI Holdings cautions recipients of such information that actual performance may vary greatly from these forecasts as a result of a variety of different factors, including changes in economic conditions or market environment.