Basic Policy on Information Disclosure

In order to provide shareholders and investors with timely, accurate, and fair information, OBC discloses information in accordance with the Financial Instruments and Exchange Act of Japan and the Timely Disclosure Rules stipulated by Tokyo Stock Exchange, Inc. (“Timely Disclosure Rules”). In addition, our basic policy on disclosure is to provide information that is useful to shareholders and investors by also fairly disclosing information that is not subject to the Timely Disclosure Rules, so as not to allow information to be concentrated in the hands of certain shareholders and investors.

Method of Information Disclosure

OBC discloses information subject to the Timely Disclosure Rules through the Timely Disclosure Network (TDnet) provided by Tokyo Stock Exchange, Inc. in accordance with the Rules. We will post the information disclosed via TDnet on our website promptly after it is released to the media.
In disclosing information that is not subject to the Timely Disclosure Rules, we make sure that such information is communicated to general investors by appropriate means as accurately and as fairly as possible, bearing in mind the purpose of timely disclosure.
As for the disclosure of financial results, in light of recent examples of large fluctuations in the performance of Japanese corporations in a short period of time, we strive to disclose quarterly and year-end financial results within one month after the closure of the respective fiscal periods.

Quiet Period

To prevent the leakage of any information that may affect share prices, such as financial information, and to ensure fairness, OBC observes a “quiet period” from ten days prior to the closure of a fiscal period to the day of the announcement of financial results. During this period, we will abstain from commenting on or responding to any inquiries about financial results and related topics. However, in the event that financial results are expected to deviate significantly from our earnings forecast during this quiet period, we will disclose the information as appropriate in accordance with the Timely Disclosure Rules.

Management Structure, Implementation of Training, etc.

OBC has established detailed rules for the handling of important company information in the Rules for the Prevention of Insider Trading (internal policy) . To deepen understanding of this policy and ensure that all employees are aware of its content, we conduct training for all new employees, including training on compliance. In addition, we post on OASIS (internal bulletin board) reminders regarding restrictions on the trading of OBC’s shares from one month prior to the timing of quarterly disclosure as well as the end of the fiscal year, to ensure that all employees are aware of these restrictions.

Spokespersons

OBC’s spokespersons are the president, the officer responsible for information disclosure, executive officers, and IR personnel. IR personnel are always present when non-spokespersons make contact with market participants as part of IR activities. In addition, we prohibit non-spokesperson officers and employees from providing IR information.

Corporate Governance Structure

Timely Disclosure Structure