Disclosure policy

1. Information Disclosure Standards

Bengo4.com, Inc. (hereafter, the "Company") will disclose information in accordance with the Companies Act, the Financial Instruments and Exchange Act, other laws and regulations, and rules on timely disclosure of corporate information (hereafter, the "Timely Disclosure Rules") stipulated in the Securities Listing Regulations of Tokyo Stock Exchange. When information has emerged related to determined facts, occurring facts, or information related to account settlement that has a significant impact on investment decisions, the Company will promptly disclose such information according to the standards stipulated in the Timely Disclosure Rules. The Company will also proactively disclose information that it deems important or valuable to investment decisions even if such information is not subject to the Timely Disclosure Rules.

2. Information Disclosure Methods

Information subject to the Timely Disclosure Rules is promptly published on the IR section of the Company's website following disclosure via the Timely Disclosure Network (TDnet) provided by the Tokyo Stock Exchange.

3. Prevention of Insider Trading

The Company has established internal rules for preventing insider trading and is promoting a thorough understanding and awareness of these rules among all of its officers and employees. In addition, to prevent insider trading, the Company appropriately manages information about material facts that has an impact on investment decisions and discloses such information promptly in accordance with laws, regulations, and Timely Disclosure Rules.

4. Quiet Period

To prevent the leakage of financial results (including quarterly results) information and to ensure the fairness of disclosure, the Company has defined an investor relations quiet period that extends from the day following the last day of the (quarterly) accounting period to the day of the announcement of financial results for the corresponding accounting period. During this period, the Company refrains from answering questions about its financial results and earnings forecasts or commenting on them. However, even during the quiet period, the Company will disclose information in an appropriate and timely manner in accordance with the Timely Disclosure Rules. Even during the quiet period, the Company will respond to inquiries about information that has already been made public.

5. Handling of Earnings Forecasts and Future Information

Any fact other than past and present facts that the Company discloses in earnings forecasts, strategies, policies, and targets are forward-looking statements. Such statements are made on the grounds of a plan, expectation, or decision made based on information obtained at the time and certain assumptions deemed reasonable. Accordingly, actual earnings results, etc. may differ materially from these forward-looking statements due to various risks and uncertainties such as economic conditions, the competitive situation, changes to laws or regulations, introduction of a new technology, and generation of an unexpected cost.

6. Development of Internal Systems/Structures

In accordance with this Disclosure Policy, the Company strives to establish and enhance its internal systems for the purpose of ensuring appropriate information disclosure by following relevant laws, regulations, and rules, such as the Financial Instruments and Exchange Act and the Timely Disclosure Rules established by the Tokyo Stock Exchange.