The OLC Group is committed to disclosing information in a fair, timely and appropriate manner based on the following disclosure policy.
1. Basic Policy on Disclosing Information
The OLC Group fairly and appropriately discloses information in a timely manner to investors and all stakeholders. Moreover, the OLC Group complies with all laws relevant to the disclosure of information, including the Financial Instruments and Exchange Law and the Rules on Timely Disclosure of Corporate Information established by the Tokyo Stock Exchange. We collect, analyze and energetically disclose information on events that may have a material impact on decisions regarding investment in OLC.
The OLC Group puts into practice its approach of management based on dialogue by working to earn the trust and mutual understanding of stakeholders through this highly transparent disclosure of information. Moreover, our management regularly listens to the opinions and evaluations of stakeholders to apply them in the future.
2. Methods of Disclosing Information
We register and disclose securities reports and other materials via the Financial Services Agency's EDINET, and information subject to the Tokyo Stock Exchange's Rules on Timely Disclosure of Corporate Information via the Tokyo Stock Exchange's TDnet. Once we have done so, we promptly disclose the same information via the OLC Group's website and the mass media.
We work to fairly and rapidly communicate information not subject to the Tokyo Stock Exchange's Rules on Timely Disclosure of Corporate Information via the OLC Group's website, the Tokyo Disney Resort website, mass media (news agencies), and other means.
3. System for Disclosing Information
The OLC Group has established and put into effect the OLC Group Information Security Policy for matters regarding the handling and management of information necessary to its corporate operations. We structure the fair, appropriate and timely disclosure of information using its rules, guidelines and procedures for handling personal and other information, publications and information systems as required, based on the policy.
In addition, the OLC Group has established the Emergency Control Center (ECC) to provide a swift and integrated response to risks including disasters, accidents and incidents that may impact its core Tokyo Disney Resort business. We have also created an organization that can rapidly respond to information risk.
Moreover, the Information Security Management Committee has built a system for monitoring and, where necessary, directing and advising the companies in the OLC Group as to whether they are conducting appropriate management of their information and information systems based on the OLC Group Information Security Policy and the regulations of each Group company. In addition, the Auditing Department of OLC periodically conducts audits of the propriety of the Committee's activities.
The OLC Group has separately established its Regulations to Prevent Insider Transactions in working to preclude insider transactions by OLC Group directors and other employees.
4. Disclosure of Future Projections
The OLC Group discloses information concerning future projections including performance forecasts, plans and strategies. These forward-looking statements are based on information available at the time of disclosure and represent the judgment of OLC's management. However, the OLC Group's operations are sensitive to influences including, but not limited to, consumer preferences, social conditions and economic developments. Consequently, recipients should be aware that information issued by OLC related to future projections contains elements of uncertainty. Business risks that may materially influence investor decisions are presented at
5. Establishment of a Quiet Period
The OLC Group prevents leakage of financial results and promotes fair disclosure by maintaining a quiet period from the day following the final day of each quarter until the day financial results are officially announced. During this period, we do not respond to any questions regarding financial results, and as a rule, provides no news for investors. However, even during the quiet period, we conduct fair, appropriate and timely disclosure of information subject to the Tokyo Stock Exchange's Rules on Timely Disclosure of Corporate Information. In addition, during the quiet period the OLC Group does not limit discussion of information that it has already disclosed.