Disclosure Policy

1. Basic Policy

Bell-Park discloses information fairly and in a timely and proper manner in accordance with the Financial Instruments and Exchange Act, other related laws and regulations, the Timely Disclosure Rules of the securities exchange where Bell-Park stock is listed, and the Fair Disclosure Rules.

2. Method of Disclosure

Bell-Park discloses information that is covered by the Timely Disclosure Rules in accordance with these rules by using the TDnet(Timely Disclosure Network) of the Tokyo Stock Exchange. Information in Securities Reports and other documents used to disclose information is made public by using the EDINET (Electronic Disclosure for Investors’ Network) system of the Financial Services Agency.
In addition, information disclosed using TDnet and EDINET is promptly posted on the Bell-Park website. Furthermore, Bell-Park discloses other information by using appropriate methods that are consistent with the spirit of timely disclosure in order to make this information available to shareholders and investors.

3. Individuals Responsible for Providing IR Information

To ensure the accuracy and fairness of information that is disclosed, Bell-Park uses the company president, directors associated with information disclosed and investor relations personnel for the disclosure of information.

4. Information concerning Fair Disclosure Rules

In the event that an individual at Bell-Park who supplies IR information discloses significant private information to a business partner or other person, the information will be made public immediately afterward by using the Tokyo Stock Exchange TDnet and the Bell-Park website.

5. Forward-Looking Statements

Financial forecasts, information on the Bell-Park website, information distributed at information meetings to announce results of operations and other information that is not historical facts are forward-looking statements. These statements are based on the judgments of management by using information available when these materials were prepared. Consequently, actual results of operations may differ from these statements due to a variety of changes involving risk factors, other uncertainties, the economy and other factors.

6. Quiet Period

Bell-Park has a “quiet period” of 15 days prior to the each announcement of quarterly results of operations because preparations are under way for this announcement. The purpose is to ensure the fairness of the disclosure of information by preventing any information leaks that could affect the stock price. During the quiet period, Bell-Park will not respond to any questions about its performance or make any comments. Nevertheless, even during the quiet period, Bell-Park will make an announcement promptly in accordance with the Timely Disclosure Rules and other guidelines if Bell-Park expects to make a significant revision to the forecast for results of operations. During the quiet period, Bell-Park will provide confirmations and other responses concerning information that has already been disclosed.

7. Prevention of Insider Trading

Bell-Park has rules for the prevention of insider trading for the purpose of properly managing important information about the BellPark Group so that insider trading does not occur. In addition, there are training programs for executives and employees to give everyone a thorough understanding of insider information management.

8. Activities for Constructive Dialogues with Shareholders

Bell-Park uses primarily the following activities for the provision of IR information, which is done mainly by individuals responsible for supplying this information. Opinions and other information received during these dialogues is distributed to senior executives and other people involved at Bell-Park in order to assist with managing operations in a manner that contributes to the growth of corporate value.

• General Meeting of Shareholders (once a year)
• Information meetings for earnings announcements for institutional investors and analysts (twice each year)
• Small meetings following earnings announcements
• Distribution of a Business Report (twice each year)
• Interviews and other meetings in response to requests from investors (throughout the year)
• Disclosure of press releases on the Bell-Park website

In addition to these activities, Bell-Park uses other methods as needed for constructive dialogues with shareholders and other investors.