①Fundamental commitment to information disclosure
Sojitz discloses information in compliance with Japan's Financial Instruments and Exchange Act, Tokyo Stock Exchange (TSE) regulations, and other applicable laws. Sojitz also proactively discloses in a timely and appropriate manner other information that is not required to be disclosed by the TSE's Timely Disclosure Rules, including material company information likely to influence investment decisions made by investors and information useful for enhancing their understanding of Sojitz's business activities.
②Internal system for timely disclosure
In accord with its fundamental commitment to information disclosure, Sojitz has established an internal system with a designated organizational unit in charge of centralized collection, management, checking, and disclosure of material information (including potentially material information).
(1)The organizational unit in charge of information disclosure is the Public Relations Department (referred to below as the "Information Disclosure Unit"). The Information Disclosure Unit collects, manages, checks, and discloses information on a centralized basis.
(2)Material or potentially material company information exists not only within Sojitz's organization but also throughout the Sojitz Group, including subsidiaries. Accordingly, the Information Disclosure Unit collects intragroup company material, or potentially material, information from the corporate departments that constitute Sojitz's administrative organization, in accord with Sojitz's internal rules for internal reporting of material information or requesting a determination regarding material information.
Group rules are applicable to subsidiaries, which are also required to report, or obtain a determination from Sojitz on material information, including information on financial results and decisions and events stipulated in the Financial Instruments and Exchange Act (insider trading regulations). During this collection process, material information is to be collected by the Information Disclosure Unit without delay or omission.
③Timely disclosure decisions
Collected information is vetted by the Information Disclosure Unit to determine if it is required to be disclosed by the TSE's Timely Disclosure Rules. As the person responsible for information handling, the General Manager of the Public Relations Department decides whether or not disclosure is required.
④Timely disclosure procedure
Information on decisions and financial results is to be disclosed without delay once the Public Relations Department's General Manager has determined that it is subject to timely disclosure requirements and, if necessary, this determination has been approved by the Board of Directors. Information on events is to be disclosed without delay once the Public Relations Department's General Manager has determined that it is subject to timely disclosure requirements. Tasks involved in timely disclosure are to be performed by the Information Disclosure Unit.
⑤Information disclosure methods
Information disclosed pursuant to the TSE's Timely Disclosure Rules is to be disclosed via the TSE's TDnet and published on Sojitz's website as promptly thereafter as possible. Additionally, in accord with the intent of timely disclosure, Sojitz endeavors to disclose to its stakeholders even information not required to be disclosed pursuant to the Timely Disclosure Rules.
⑥Documents to be disclosed
Mandatorily disclosed documents: summaries of financial results, public notices of financial results, securities reports (quarterly reports), other documents subject to timely disclosure requirements
Voluntarily disclosed documents: presentation materials from results briefings, annual reports (including CSR reports), communications distributed to shareholders, and news releases
Other documents published on Sojitz's website
(Timely Disclosure Framework)