Mitsubishi Steel proactively discloses information to its shareholders and other investors in a fair, timely, and appropriate manner, pursuant to the Mitsubishi Steel Group Code of Conduct and its Basic Policy for Corporate Governance.
Moreover, we engage in constructive dialogue with our shareholders and other investors with the aim of achieving sustainable growth and heightening our corporate value over the medium and long term.

1. Basic attitude toward disclosure

Mitsubishi Steel discloses information in accordance with Japan's Financial Instruments and Exchange Act, other laws and regulations, and the Securities Listing Regulations as stipulated by Tokyo Stock Exchange, Inc. (TSE). We also disclose information deemed significant in a fair and prompt manner, even when such information is not subject to statutory and timely disclosures.

2. Methods of disclosure

We release timely disclosure information via the Timely Disclosure Network (TDnet) operated by TSE, in accordance with the Securities Listing Regulations stipulated by TSE. We also release information subject to disclosure in accordance with Japan's Financial Instruments and Exchange Act via the Electronic Disclosure for Investors' NETwork (EDINET) operated by Japan's Financial Services Agency, and then promptly make it available via the Mitsubishi Steel website.
Moreover, we release other information deemed significant through appropriate means.

3. Framework for dialogue with shareholders and other investors

Members of our senior management team actively participate in dialogue with our shareholders and other investors, premised on the notion that investor relations are a critical business priority. Moreover, the Director in charge of the Public Relations and Investor Relations Department acts as the executive officer that handles matters involving dialogue with shareholders and other investors, and in that capacity heads initiatives that entail coordination with the Corporate Planning Division, Public Relations and Investor Relations Department, General Affairs & Human Resources Department, Accounting Department, and other operations.

4. Constructive dialogue with shareholders and other investors

The Director in charge of the Public Relations and Investor Relations Department and our senior management team strive to engage in positive interactive dialogue with our shareholders and other investors, to the extent reasonably possible. We also establish forums for dialogue with shareholders and promptly make CSR reports and biannual reports for shareholders available via the Mitsubishi Steel website. For overseas investors, we also provide information by posting English-language versions of our financial statement summaries and notices of convocation of ordinary general meetings of shareholders.
To ensure constructive investor dialogue, our representative directors and other members of senior management also provide explanations pertaining to earnings results and business strategy twice annually at our financial results briefings geared to analysts and institutional investors.
Opinions that we receive in the course conducting dialogue with shareholders and other investors are reported as necessary to our representative directors and also to our Board of Directors, and are also employed in the course of formulating our business strategy.

5. Measures for managing confidential information

We have a framework for providing guidance on overall matters involving the management of confidential information, and have accordingly established a secretariat to which the Director in charge of the General Affairs & Human Resources Department acts as the Confidential Information Control Officer, on the basis of our Confidential Information Management Rules. Moreover, we implement measures with respect to our handling of information to ensure that we do not act in violation of insider trading regulations. To that end, we have drawn up the Insider Trading Control Regulations and the Confidential Information Control Manual to ensure thorough information management practices, and also have the Director in charge of the Public Relations and Investor Relations Department and other members of our senior management team to handle matters involving outside reporting and coverage of our firm.
We also mandate a period of time during which restrictions are placed on providing comments regarding financial performance and replies to questions in that regard, in order to ensure fairness and to prevent situations where earnings results could be leaked or otherwise divulged.