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Disclosure Policy

1. Basic Policy on Disclosure

Capcom Co., Ltd. (hereinafter Capcom) believes that it is the responsibility of a listed company, as well as a necessity in terms of corporate governance, to disclose information to shareholders and investors in a timely and appropriate manner and fulfill its accountability adequately. As such, Capcom will maintain high transparency in the management of its business by taking the following basic stance in promoting IR activities: (1) Establishment of a responsible IR system, (2) Satisfactory information disclosure, and (3) Establishment of a system for timely disclosures.

2. Disclosure Standards

Capcom follows the “Security Exchange Law” and related regulations, and the “Timely Disclosure Regulations” established by the “Tokyo Stock Exchange” (hereinafter TSE) in order to provide accurate, fair and timely disclosures to the extent possible.
Capcom also intends to establish a policy of timely and fair disclosure of corporate information to meet investors’ demands, such as briefings of financial results through our website as well as printed materials, which are not subject to the above regulations.

3. Timely Disclosure Structure

4. Quiet Period

To prevent the unauthorized disclosure of quarterly earnings information prior to official announcements, Capcom has established a quiet period starting approximately one month prior to the scheduled earnings announcement. During this period, we refuse all inquiries relating to our business performance. However, if significant changes to our earnings outlook are anticipated during the quiet period, we will disclose this information pursuant to the Timely Disclosure Rules and other regulations.

5. 12-hour Rule

There are cases in which the information presented on this website falls under the definition of Material Facts as stipulated by the Financial Instruments and Exchange Act (FIEA) and Timely Disclosure Rules. Further, there are cases in which individuals who obtain said information from this website fall under the definition of a primary recipient of information as specified by Article 166 of the FIEA, which stipulates regulations for insider trading.

Accordingly, because there is a risk that individuals who have obtained said information from this website and who buy and sell stock in our company will be subject to insider trading regulations we ask that you exercise caution.

However, individuals will not be subject to these regulations in the cases of the following announcements.

1.When said information has been public for at least 12 hours via at least two news/media organizations as stipulated in Article 30, Paragraph 1 of the Enforcement ordinance of the FIEA.

2.When said information has been provided for public inspection via electromagnetic record as defined by the Cabinet Office Ordinance of the stock exchange.

6. Framework for IR Activities

Capcom IR activities are conducted by three full-time staff members in addition to the chairman, the president and the IR director on behalf of shareholders and investors in Japan and overseas. For earnings information and other IR-related inquiries, please use the contact information below.

Public Relations & Investor Relations Section
Telephone: +81-6-6920-3623
E-mail: ir@capcom.co.jp
Business Hours: 9:00-12:00, 13:00-17:30 (JPN)
(excluding weekends and holidays)