Disclosure Policy

Japan Eyewear Holdings Co., Ltd. (“JEH”) will make information disclosure in accordance with the Financial Instruments and Exchange Act and other laws and regulations, as well as the timely disclosure rules set by the Tokyo Stock Exchange. In addition, JEH will endeavor to make prompt and fair disclosure of information even beyond those specified as disclosure matters under the timely disclosure rules by regarding any information that may impact the investment decisions of investors as material corporate information. Through IR activities, JEH will seek to communicate with shareholders and investors in an aim for greater soundness of corporate management and enhancement of shareholder value.

JEH defines disclosure information into the following three types.

• Timely Disclosure Information
  Material information under the timely disclosure rules set by the Tokyo Stock Exchange.
  Efforts are made to ensure that timely disclosure information on corporate decisions are disclosed promptly after the Board of Directors’ resolution/ approval.
• Voluntary Disclosure Information
  Information not falling under 1., but are those that may impact the investment decisions of shareholders/ investors.
• Other PR Information
  Public relations (PR) information concerning stores, products and other corporate activities.

For timely disclosure information and voluntary disclosure information, the documents will be registered with TDnet (Timely Disclosure network) and then posted on the JEH website.

• Department in Charge of Timely Disclosure
  At JEH, the president is responsible for overseeing the promotion of IR activities. With the entity responsible for handling of information (the CFO) as the officer in charge of IR and the chief department for timely disclosure as the department in charge of IR thereunder, information is grasped and documents prepared and disclosed in close coordination with relevant departments.
  In addition, the department in charge of IR is also the one responding to inquiries and so forth from market participants, shareholders and investors.
• Grasp of Timely Disclosure Information
  The entity responsible for handling of information and the department in charge of IR endeavor to collect information on each department’s status of progress of measures and so forth as appropriate. In addition, the IR department endeavors to collect detailed information by interviewing related departments as appropriate.
  When information subject to timely disclosure is expected to arise, the department handling the information will report such promptly to the entity responsible for handling of information and the department in charge of IR.
• Preparation and Disclosure of Timely Disclosure Documents
  At JEH, the accounting department heads the preparation of earnings reports and other accounting disclosure documents. In addition, for matters concerning shares, key personnel changes and so forth, the general affairs department heads the preparation of reference documents, and the entity responsible for handling of information and the department in charge of IR conduct a final review of the contents in the preparation and disclosure of timely disclosure documents.
• Management of Timely Disclosure Information
  Internal rules on inside information are in place to ensure the confidentiality of timely disclosure information. In addition, under the management of the entity responsible for handling of information, efforts will be made to prevent external leak of insider information and prevent insider trading by internal parties.

• Establishment of Framework for Realization of Constructive Dialogue
  At JEH, IR activities are recognized as one of the key management tasks and the president is responsible for overseeing the promotion of IR activities as stated under “Framework for Timely Information Disclosure” above. Earnings briefings are held every fiscal quarter, all of which are attended by the president and the officer in charge of IR, and at which medium- to long-term strategies and progress of priority measures for the fiscal year are explained, Q&A sessions conducted and so forth.
  For enhancement of information disclosure, an IR department has been installed directly under the officer in charge of IR, establishing a framework for constructive dialogue with shareholders and investors. In addition, the president and the officer in charge of IR attend small group meetings and one-on-one meetings as necessary to engage in constructive dialogue with shareholders and investors. The opinions, requests, concerns, etc. gathered from IR activities are communicated as feedback to the executives and corporate-wide as appropriate in an aim to enhance corporate value.
  The IR department seeks organic cooperation with each internal department to ensure proper response. In addition to the matters stated under “Grasp of Timely Disclosure Information,” matters to consider such as changes in the external environment and legal and regulatory trends relating to business operations are shared.
• Forms of Dialogue
  The IR department promotes both direct IR activities, which are targeted at mainly analysts and institutional investors, and indirect IR activities, which are targeted at retail shareholders, retail investors and certain institutional investors.
  Direct IR activities include proactively holding not only an annual average of 200 to 300 or so one-on-one analyst/ investor meetings but also factory and store tours as well as other initiatives in efforts to foster greater understanding of JEH’s corporate management and business operations.
  Indirect IR activities are mainly the pursuit of an enhanced IR website.
  With the IR website, initiatives are underway for investors coming into contact with JEH for the first time to gain an understanding of JEH in a short amount of time through the development of section outlining the management philosophy, business model, long-term vision, policy on return to shareholders, FAQs, etc., in addition to posting earnings reports, securities reports, and other statutory disclosure documents and timely disclosure information. For information on earnings briefings, the presentation materials and transcripts outlining the presentation content and Q&As of the briefings are promptly posted to make the same information accessible to those who did not attend the briefings.
• Grasp of Shareholder Composition
  JEH endeavors to have a substantial grasp of shareholder composition from not only information available from the shareholder register but also mainly statements of large-volume holdings, public information on investors’ investment portfolio and so forth. Efforts are made to have a substantial grasp of shareholder composition from also investor meetings’ interview/ discussion content, meeting frequency, etc. Through such information, JEH proactively takes the initiative to promote IR activities along with promoting constructive dialogue with shareholders and investors.
• Measures for Greater Capital Efficiency
  JEH will seek to enhance capital policies through better dividend payouts and purchase of own shares while at the same time utilizing cash earned from driving the business in investments for medium- to long-term growth. By carrying out agile financial and capital policies, greater capital efficiency will be sought along with supporting operating activities in an aim to enhance value for all stakeholders.

In order to prevent the leak of financial-related information, the period from the day following each fiscal quarter end until that fiscal quarter’s earnings announcement is set as a quiet period during which JEH refrains from responding to any comments or inquiries regarding the settlement of accounts prior to the announcement. However, disclosure will be made as appropriate when an event has occurred during the quiet period that is specified as a disclosure matter under the timely disclosure rules or when expecting a large discrepancy from the earnings forecasts that have been announced and disclosure during the quiet period is deemed necessary.

Any current plans, outlooks, strategies, etc. of JEH posted on this website that are not historical facts are forecasts of future business performance and these are based on the judgments of JEH made in light of the information currently available to it. Please note that actual business results may differ from these forecasts.