WILL GROUP

Disclosure Policy

1.Basic Policy on Information Disclosure

We strive to provide timely and appropriate disclosure of information based on transparency, fairness, and continuity, to all stakeholders, including shareholders and investors.

2.Criteria for Information Disclosure

The Company conducts swift information disclosure based on transparency, fairness, and continuity, following the various laws and regulations, such as the Financial Instruments and Exchange Act and the securities listing regulations stipulated by the Tokyo Stock Exchange. In addition, even when information does not correspond to material facts as stipulated by laws and regulations and securities listing regulations, etc., the Company will provide proactive and fair disclosure as far as possible if it judges the information to be of use to shareholders and investors.

3.Methods for Information Disclosure

Disclosure of information corresponding to material facts as stipulated by securities listing regulations is conducted in accordance with the regulations through the Timely Disclosure Network (TDnet) provided by the Tokyo Stock Exchange. After the informatoin is disclosed through TDnet, it is also posted promptly on the Company’s website. In addition, even information that does not correspond to regulations, etc., will be disclosed appropriately and promptly in accordance with its degree of importance and urgency if it is judged to be important or beneficial.

4.Future Outlook

The earnings forecasts, future outlooks, strategies, targets, and so forth disclosed by the Company that are not related to past or present facts contain statements regarding future outlooks and include risks and uncertainties including changes in economic conditions, market trends, taxation systems and other systems. Therefore, the actual results that are announced in the future may vary due to these various factors.

5.Quiet Period

The Company observes a quiet period from the day following the financial closing date (quarterly reporting) until the day of announcement of the financial results so as to prevent leakage of financial results information and ensure fairness. During this period, the Company will refrain from commenting or answering questions regarding its financial results. However, in the event that the Company comes to expect a major deviation from the earnings forecast during this period, it will disclose such information appropriately. Moreover, notwithstanding the quiet period, the Company will respond to questions regarding information that has already been disclosed.

6.IR Activities

Regular investor briefings for analysts of the administrator of the shareholder registry and institutional investors

We hold four quarterly briefings a year for analysts and institutional investors.

Posting IR Materials on the Company Website

IR materials such as financial results information and financial results presentation slides are posted on the Company’s website in English as well.

Other

We conduct individual meetings with analysts, institutional investors, and overseas investors as needed. We also participate in conferences held by securities companies as needed.