Seven Bank Disclosure Policy

Seven Bank, Ltd. (hereinafter, the “Company”) seeks to provide accurate information on its financials and business strategies to shareholders, investors, securities analysts and rating institutions (hereinafter, the “Market”) in a prompt, equal and easy-to-understand manner to help them deepen their understanding about the Company and to reflect the Market’s evaluation of the Company to its management. The Company thereby aims to increase its medium and long-term corporate value and achieve sustainable growth. To this end, the Company conducts its investor relations activities based on the following basic policy:

1. Basic policy concerning constructive dialogue with shareholders/investors

The Company believes that constructive dialogue with shareholders/investors contributes to increasing the Company’s medium and long-term corporate value and achieving sustainable growth. The Company has formulated a policy concerning related engagement.

2. Basic Policy concerning Information Disclosure

The Company’s basic policy is to disclose fair and transparent information to shareholders/investors and all other stakeholders. To obtain adequate evaluation of its corporate value, the Company ensures that its information disclosure adheres to applicable laws and regulations, securities listing regulations and other relevant rules. Furthermore, to help shareholders/investors and all other stakeholders further deepen their understanding about the Company, the Company seeks to proactively disclose information which it deems to have an impact on shareholders’ and investors’ judgment even when disclosure of such information is not required by the relevant laws and regulations, the securities listing regulations and other relevant rules.

(1) Criteria for information disclosure

The Company discloses the following types of information:

(2) Method of information disclosure
The Company discloses statutory information required by Financial Instruments and Exchange Act and information required by Securities Listing Regulations and other relevant rules through, respectively, EDINET (an electronic disclosure system for securities reports and other disclosures required by Financial Instruments and Exchange Act) and TDnet (a timely disclosure communication system provided by Tokyo Stock Exchange). Additionally, in principle, the Company promptly posts information on its website. Furthermore, the Company holds financial results briefings for analysts and institutional investors in Japan and briefings for individual investors, publishes integrated reports and take other measures to help them better understand its business.

(3) Quiet period
The Company designates as a quiet period the approx. three weeks prior to the release of financial results to prevent financial information leak and ensure fair disclosure. During this period, the Company refrains from commenting on its financials, responding to questions, holding meetings, etc. Nevertheless, even during the quiet period, the Company responds to inquiries about information not relating to the financial results and information that is already publicly known. Any events occurring during the quiet period that fall within the criteria for timely disclosure are disclosed in accordance with the Timely Disclosure Rules.

(4) Description of forward-looking projections
Information disclosed by the Company may include statements concerning forward-looking projections. Such statements represent judgment of management based on information available at the time of disclosure. They are also based on certain assumptions for making forward-looking projections and contain various risks, indeterminacies and uncertainties. Therefore, actual performance numbers and results may differ from the future projections included in the disclosures due a range of factors such as future business operations and changes in economic situations.

End of Document