Information Disclosure Policy
1. Basic Policy
Mitsubishi HC Capital Inc. (the “Company”) shall maintain the proactive and ongoingdisclosure of information, with the aim of winning the trust of its diverse stakeholders,
including shareholders and investors, and earning their appreciation. Moreover, theCompany shall develop an in-house structure for ensuring that information associatedwith its management policies, business strategies, business activities, financial position,and other matters is disclosed in an accurate, timely and fair manner. In addition, we shallmaintain a fair and responsible approach to information disclosure through engagementwith stakeholders via various communication activities.
2. Basic Principles
With regard to the disclosure of “material information,” the Company shall adhere to thefive basic principles listed below.
(1) Transparency
We shall ensure the fact-based disclosure of information no matter the content.
(2) TimelinessWe shall disclose information in a timely manner and immediately upon the occurrenceof an event that warrants disclosure.
(3) Fairness
We shall ensure that disclosed information is communicated broadly to a variety of
stakeholders in a fair manner.
(4) Continuity
We shall disclose information in a continuous manner.
(5) Confidentiality
We shall not provide information to third parties before such information has officiallybeen announced.
3. Disclosure Standards
In addition to disclosing mandatory items specified under the rules of stock exchanges,
the Financial Instruments and Exchange Act, or other laws and regulations requiring
disclosure, we will take a self-directed and proactive approach, disclosing otherinformation considered helpful to our stakeholders.

4. Methods for Information Disclosure
We shall publicize corporate information requiring timely disclosure through the Timely
Disclosure Network (TDNet) run by the Tokyo Stock Exchange while posting suchinformation on our corporate website from the perspective of ensuring its timeliness andpublic availability. Furthermore, we shall update our shareholders about the Company’sbusiness activities via reporting documents and otherwise facilitate stakeholder
understanding of its wide- ranging business endeavors by, for example, holding investor
briefings. In the course of disclosing information through these methods, we shall comply
with relevant laws and regulations, including the Financial Instruments and Exchange Act.
5. Handling of Material Information That Has Yet to Be Publicized
When we handle inquiries, respond to press interviews, hold such meetings as financial
results briefings or participate in similar events, we shall not present material informationthat has yet to be publicized. Explanations provided on these occasions shall pertain only
to facts that are already publicized or known to the general public. Also, the Company
shall strictly manage insider information to prevent information leakage and maintain theimpartial disclosure of information.
6. Quiet Period
The Company shall refrain from making comments related to operating results forecasts
during approximately one month prior to the announcement of quarterly and annual
results (the “quiet period”). Notwithstanding the foregoing, the Company may defy thequiet period upon emergence of a significant fact requiring timely disclosure inaccordance with timely disclosure rules of stock exchanges or otherwise warranting theissuance of an extraordinary report.
7. Development of an In-House Structure
In order to maintain appropriate information disclosure in line with the abovementioned
policies, the Company shall strive to develop an optimal in-house structure, with officers
and business units in charge of communications playing a central role and all otherrelevant departments acting in organic collaboration. The Company shall also ensure that
opinions gleaned via stakeholder dialogue and deemed to contribute to enhancing
corporate value are shared internally, on an as-necessary basis, and adequately addressed.

8. Prohibition of Selective Disclosure
In order to maintain the fairness, impartiality and appropriateness of information
disclosure for shareholders, investors, securities analysts and other participants in thecapital market, the Company shall not engage in selective disclosure. Selective disclosurerefers to the communication of important information, which has yet to be publicly
released, to selected individuals or groups prior to the public announcement of suchinformation. The Company shall thus refrain from disclosing information in this mannerunless the secrecy of such information is protected by a robust confidentiality agreement.
9. Response to the Spread of Market Rumors
In principle, the Company shall not comment on inquiries about market rumors. However,
if it is determined that not responding to a rumor could seriously impact the Company,
we shall implement appropriate measures to counter the spread of the rumor.
Establishment: April 1, 2021