Disclosure Policy

1. Basic Policy

It shall be acknowledged that adequate disclosure is an important element in the disclosure of corporate information of the ROHM Group (hereinafter referred to as the "Company"), and every member of the Company is required to disclose information in an appropriate manner in compliance with the provisions of these Rules.

2. Principles of Information Disclosure

For the purpose of Information Disclosure, the following principles shall be observed.


2.1 Transparency and Accountability


Information Disclosure shall be made based on actual facts without regard to the advantage or disadvantage to the Company resulting therefrom, in order thereby to ensure transparency and accountability.


2.2 Compliance with relevant laws and regulations


Information Disclosure shall be made in compliance with the Financial Instruments and Exchange Law and other relevant laws and regulations, and the generally accepted rules for Information Disclosure including the listing rules of the stock exchange on which the shares of the Company are listed.


2.3 Timely Disclosure and Confidentiality


Information Disclosure shall be made in a prompt manner while safeguarding the confidentiality of confidential information.


2.4 Disclosure in the Public Interest


Information Disclosure shall be made through a press release held at the press club of the stock exchange, an announcement on websites or other appropriate means, in a manner allowing the shareholders and the public easy access to the information disclosed. Except where the confidentiality of information is protected under a confidentiality agreement, Information Disclosure shall not be made in a selective manner.


2.5 Obligation of Confidentiality


The directors, officers and employees of the Company are prohibited from disclosing information in a manner other than in accordance with the manner and procedures set forth in these Rules. In cases where any information subject to these Rules is required to be disclosed to a party outside the Company, it shall be ensured in advance that the confidentiality of the information disclosed will be protected under a confidentiality agreement or other appropriate arrangement to safeguard the confidentiality.