NIPPON MINING HOLDINGS,INC. | Investor Relations | Management Policy

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Disclosure Policy

1. Basic Policy: Nippon Mining Holdings (hereinafter the "Company") is committed to the disclosure of information to shareholders and investors in a timely, appropriate and fair manner, thereby improving the transparency of its corporate management. In disclosing information, the Company adheres to applicable laws and regulations. Furthermore, the Company actively communicates its managerial policies along with management and financial information to its stakeholders to enable them to build an extensive understanding of the Nippon Mining Holding Group's business activities. The Company seeks to increase opportunities for corporate management to speak directly with a greater number of shareholders and investors through earnings meetings, medium term management plan meetings and other events, while also seeking to communicate information in a fair and clear manner through this web site.
2. Disclosure Standards: Pursuant to the Corporate Law, Financial Products Exchange Law and related laws and regulations, and the Timely Disclosure Regulations stipulated by the Tokyo Stock Exchange (TSE) (hereinafter the "Timely Disclosure Regulations"), the Company discloses information via TDnet, the timely disclosure network system operated by the TSE. Although the Company has a policy of promptly publishing on this web site any information disclosed on TDnet, such information may appear on this web site much later than the time of disclosure on TDnet due to factors such as the taking time to prepare the information. With regard to information disclosures not required under the Corporate Law, Financial Products Exchange Law and related laws and regulations, or the Timely Disclosure Regulations, the Company, in consideration of the objective of timely disclosure, makes every effort to convey the information to shareholders and investors as accurately and as fairly as possible in an appropriate manner.
In situations where TDnet is unable to display, information that has already been posted by the Company on TDnet, due to problems with the system, individuals obtaining such information from this web site and trading the Company's shares within 12 hours of the information becoming available on this web site may be regarded as having infringed on insider trading regulations. The Company therefore urges those who intend to trade the Company's shares to view this web site as well as TDnet and other information sources before trading the shares.
3. Silence Period: To prevent financial information from leaking, the Company designates the three-week period prior to the date of earnings announcements as the "silence period". The Company will withhold response to inquiries regarding account settlement during the silence period. The Company will, however, disclose information when earnings results are expected to differ significantly from any earnings forecasts that have already been announced.

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