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Disclosure Policy

1. Basic Policy

ROHM ("the Company")acknowledges the importance of timely and adequate information disclosure and the basic policy is to disclose information in accordance with following principles.

2. Principles of Information Disclosure

2.1 Transparency and Accountability

Information disclosure shall be made usefully for investors, transparency for information disclosure shall be ensured and accountability shall be made by actual facts consistently.

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, the generally accepted rules for information disclosure including the listing rules of the stock exchange on which the shares of the Company are listed, and the Company's regulations relevant to information disclosure.

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, an announcement on websites or other appropriate means, in a manner allowing the shareholders and the public easy access to the information disclosed. Information disclosure shall not be made in a selective manner, except where the confidentiality of information is protected under a non-disclosure agreement.

2.5 Obligation of Confidentiality

The directors, officers and employees of the Company are prohibited from disclosing information in a manners other than in accordance with the manner and procedures set forth in this Policy. In cases where confidential information 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 non-disclosure agreement or other appropriate arrangement to safeguard the confidentiality.

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