Disclosure Policy

1. Information Disclosure Policy
To provide timely and appropriate company information to shareholders and investors, Tamron engages in disclosure in accordance with the Financial Instruments and Exchange Act, related laws and regulations, and based on the timely disclosure rules set forth by the Tokyo Stock Exchange. We also proactively disclose other information deemed to have an effect on the investment decisions made by shareholders and investors.

2. Means of Information Disclosure
Timely disclosures are made through the “TDnet” timely disclosure information transmission system operated by the Tokyo Stock Exchange, and are also posted to the company website promptly thereafter. We also widely disclose information that does not fall under timely disclosure rules through posts to the company website and elsewhere.

3. Handling of Insider Information
Tamron appropriately manages important information and has established internal regulations to prevent insider trading. We disseminate requirements among all Group employees and endeavor to promote understanding and awareness of the rules. In addition, company directors in their capacity as information managers and the Corporate Strategy Unit in its capacity as the department responsible for disclosure ascertain and manage information concerning important matters, and develop systems for timely disclosure.

4. Quiet Period
To prevent the leaking of the company’s financial results (including quarterly results) and ensure fairness, a quiet period is established from the day following the close of a fiscal term to the day on which the financial results are announced. During this period, Tamron shall refrain from responding to questions or commenting on the company’s financial results or financial outlook. However, if an expectation that results will differ materially from earnings estimates emerges during this quiet period, an appropriate announcement will be made in accordance with the disclosure rules.

5. Spokesperson
From the viewpoint of ensuring the accuracy of information and the fairness of disclosure, Tamron’s spokespeople are the Representative Director, the Director in charge of IR, the General Manager of the Corporate Strategy Unit and the Manager of the Corporate Planning Dept. of Corporate Strategy Unit.

IR activities

Regular briefings for individual investors
Tamron holds several such briefings each year, mainly at securities firms’ offices.
Regular briefings for analysts and institutional investors
Tamron holds interim and full-year financial results briefings for institutional investors. Ever since the full-year financial results briefing for the fiscal year ended December 31, 2017, it has been holding briefings on the same date as the announcement of results. Presentation materials and explanations are published on Tamron’s website in an effort to achieve the timely and impartial distribution of information and to enhance published information. In addition, directors and other personnel visit institutional investors separately.
Regular briefings for overseas investors
Every year, Tamron takes part in a conference for overseas investors that is organized in Japan by securities firms.
Establishment of IR-related organization and appointment of staff for it
Tamron has appointed a director responsible for IR. The Corporate Strategy Unit acts as the organization in charge of IR to build a system and take actions for ensuring constructive dialogues with shareholders in collaboration with other internal departments.

Flowchart of Timely Disclosure Procedure