Fundamental Policy on Information Disclosures

Aval Data Corporation (the “Company”) strives to provide information to shareholders and investors promptly based on transparency, fairness, and continuity.

When disclosing information, the Company provides accurate, fair, and timely information in compliance with applicable laws and regulations including the Companies Act and the Financial Instruments and Exchange Act as well as rules relating to the timely disclosure of corporate information specified in the securities listing rules of the Tokyo Stock Exchange (the “rules on timely disclosure”). In addition, we proactively and fairly disclose information not covered by the rules on timely disclosure that we believe would be useful to shareholders and investors.

Disclosure Methods

The Company classifies information to be disclosed into three categories—regulatory disclosure information, timely disclosure information, and voluntary disclosure information—according to the specifics of the information.

In principle, we register and provide regulatory disclosure information and timely disclosure information to the EDINET (an electronic disclosure system for disclosure documents, such as securities reports, specified in the Financial Instruments and Exchange Act) provided by the Financial Services Agency or the TDnet (Timely Disclosure network) operated by the Tokyo Stock Exchange in accordance with laws, regulations, and rules relating to the disclosure of information including the rules on timely disclosure. We announce the details of disclosures to news media without delay and also promptly post the information on the Company’s website. There may be a delay in posting such information online due to system-related conditions.

Voluntary disclosure information is information other than regulatory disclosure information and timely disclosure information that the company voluntarily discloses. We strive to accurately and fairly disclose information using appropriate methods in light of the purposes of the rules on timely disclosure.

Earnings Forecasts and Predictions

The Company endeavors to increase the predictive accuracy of earnings forecasts and predictions released by the Company to the greatest extent possible, but this information is based on determinations and assumptions made on the basis of information that is available at the time. Therefore, actual results may differ substantially from forecasts due to changes in risks or uncertain elements or changes in economic conditions or other factors.

Embargo Periods

To prevent leaks of financial results information (including quarterly information) and to ensure fairness, the Company sets an embargo period from the day after the day of settlement until the day of announcement of financial results.
During such periods, the Company refrains from responding to questions and commenting on financial results.
However, if it is expected during an embargo period that an earnings forecast will be missed by a considerable margin, the Company will make an appropriate announcement in accordance with the rules on timely disclosure.