SGH

Disclosure Policy

1. Basic Policy on Information Disclosure

SG Holdings Co., Ltd. ("SG Holdings") sets a basic policy to disclose information in a fair, timely and appropriate manner, aiming to achieve 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." Furthermore, it is our basic policy to actively engage in a constructive dialog with market participants including our shareholders and investors, etc., to achieve sustained growth and enhance the medium- to long-term value of the Company.

2. Criteria for Information Disclosure

SG Holdings observes the provisions of the Financial Instruments and Exchange Act and other laws, rules on timely disclosure ("Rules for Disclosure") as defined by the Tokyo Stock Exchange and "Fair Disclosure Rules" to disclose information in a fair, timely and appropriate manner while ensuring the accuracy of the content of the disclosure. This is in order to meet the strong demand for information disclosure from our stakeholders including shareholders and investors, etc. 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. Disclosure Covered by the Policy

This policy covers disclosure of information by the following means.

(1) Statutory disclosure

Disclosure pursuant to the Financial Instruments and Exchange Act Annual Securities Reports, Quarterly Securities Reports, Internal Control Reports, Extraordinary Securities Reports, etc.
Disclosure pursuant to the Companies Act Business Reports, Non-Consolidated Financial Statements, Consolidated Financial Statements, etc.

(2) Disclosure required by the Tokyo Stock Exchange

Timely Disclosure Decisions and facts that the Tokyo Stock Exchange requires to be disclosed in a timely manner
Other Corporate Governance Report

(3) Disclosure of other information

IR-related materials, Integrated Reports and other voluntary disclosure materials

4. Method of Information Disclosure

SG Holdings discloses information that falls under the criteria for the Rules for Disclosure through TDnet, a system for timely disclosure of information provided by the Tokyo Stock Exchange, and disclosure documents including Annual Securities Reports pursuant to the Financial Instruments and Exchange Act through electronic disclosure system EDINET. Furthermore, in consideration to transmitting the information to our stakeholders including shareholders and investors, etc., in a fair and accurate manner, the disclosed information is posted promptly on the Company's website as necessary and efforts are made to disclose the information not only in Japanese but also in English.

5. Internal Systems for Disclosure

SG Holdings has the following internal systems for ensuring a fair, timely and appropriate disclosure of information.

6. Prevention of Insider Trading

SG Holdings has stipulated the basic matters to be observed in the "SG Holdings Insider Trading Prevention Regulations" regarding appropriate management of internal information and trading of stocks, etc. This is in order to prevent insider trading by disseminating insider trading restrictions and establishing appropriate management system for stock trading.

7. Quiet Period

In order to prevent leaks of financial information before announcement and to ensure fairness, SG Holdings observes a quiet period from the closing date (including quarterly closing date) 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.

8. 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.

As for these statements, we continuously ascertain and analyze changes in the assumed external environment and revise them as needed in the event of a certain deviation from the initial content of disclosure, and fairly, timely and appropriately disclose such revision to stakeholders including shareholders and investors, etc.

9. Dialog with Shareholders and Investors, etc.

(1) System for dialog with shareholders and investors, etc.

The Director in charge of Corporate Planning is responsible for dialog with shareholders and investors, etc., which is conducted by management centered on the President and Directors in charge of the Group's core businesses within reasonable limits as needed, in addition to being handled by the Investor Relations Office, which is a dedicated department.

Furthermore, the Investor Relations Office coordinates with the relevant departments within the Company and Group companies through regular sharing of information, etc., and support constructive dialog by management with shareholders and investors, etc.

(2) Means of dialog

The main means of dialog with shareholders and investors, etc. include individual meetings by management with domestic and overseas shareholders and investors, etc., financial results briefings, briefings on management plans and small meetings, conducting dialog to deepen mutual understanding such as providing explanations on the Company's management strategy, business model and initiatives to enhance medium- to long-term corporate value.

Furthermore, the members of the Investor Relations Office provide updates on business conditions and explanations of financial information through individual meetings and small meetings with shareholders and investors, etc. in an effort to promote understanding of the Company.

(3) Feedback on dialog

Opinions and assessments received through dialog with shareholders and investors, etc. are shared with management and broadly throughout the Company, and used as a reference for initiatives aimed at enhancing the Company's medium- to long-term corporate vale and for making explanations of the Company's management strategy and business model more easily understandable and more useful.

Inquiries concerning information on investor relations

Investor Relations Office

Telephone: +81-75-693-8850
E-mail: sgh_ir@sg-hldgs.co.jp
Business hours: 9:00 a.m. to 5:00 p.m. weekdays (excluding weekends, public holidays and year-end/New Year holidays)