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Disclosure Policy

1. Basic Policy on Information Disclosure

SG Holdings Co., Ltd. (“SG Holdings”) makes it our basic policy to actively disclose information in the aim of achieving highly transparent management to maintain and develop relationships of trust with our various stakeholders, including our shareholders, investors, customers, business partners, employees and local communities based on our corporate philosophy of “Trust, Create, and Challenge.”

2. Criteria for Information Disclosure

SG Holdings observes the provisions of the Financial Instruments and Exchange Act and other laws as well as the rules on timely disclosure as defined by the Tokyo Stock Exchange (“Rules for Disclosure”) and engages in fair and highly transparent disclosure of information as appropriate in order to meet the strong demand for information disclosure from our stakeholders. We also disclose information that does not fall under the criteria within the Rules for Disclosure in a fair and proactive manner when we consider it useful to our stakeholders for understanding our management policies and the content of our business.

3. Method of Information Disclosure

SG Holdings discloses information that falls under the criteria for the Rules for Disclosure using TDnet, a system for timely disclosure of information provided by the Tokyo Stock Exchange. Information disclosed on TDnet is also promptly posted on the Company's website as necessary as part of our efforts to ensure that the information is communicated to our stakeholders in a fair and accurate manner.

4. Quiet Periods

In order to prevent leaks of financial information before announcement and ensure fairness, SG Holdings observes a quiet period prior to the announcement of business results. During this period, we do not comment on or answer questions concerning business results or forecasts. However, in the event that results are expected to differ substantially from forecasts, SG Holdings will disclose such information as appropriate under the Rules for Disclosure.

5. Forward-Looking Statements

Statements made by SG Holdings with respect to plans, forecasts and strategies that are not historical facts are forward-looking statements involving reasonable assumptions based on information available at the time of disclosure. These forward-looking statements include risks and other uncertainties related to economic trends, market demand and various other factors.

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