Disclosure Policy
1. Basic Policy
MITSUI-SOKO HOLDINGS Co., Ltd. (“the Company”), as a member of society, strives tocontribute to the happiness of as many people as possible through our sincere activities. In order tomaintain and develop relationships of trust with various stakeholders around us, including
shareholders, investors, clients, business partners, employees, and local communities, the Company
will disclose information in a fair and transparent manner, and respond responsibly to stakeholders
through various communication activities.
2. Information Disclosure Standards
The Company will appropriately disclose necessary information in a fair and transparent manner inaccordance with laws and regulations as well as the Timely Disclosure Rules established by theTokyo Stock Exchange. In addition to information required to be disclosed by laws, regulations andthe Timely Disclosure Rules, the Company will actively disclose important management andfinancial information that is judged to be helpful for deepening stakeholders' understanding of ourmanagement policies and business activities, as well as nonfinancial information such asenvironmental and social information.
3. Documents and Acts to Disclose based on this Policy
The Company will disclose the following documents and acts in accordance with this Policy.
Documents and acts subject to statutory or timely disclosure are not limited to the following. If any
additional requirements are provided by laws and regulations, the Company will comply with them.
i. Statutory Disclosure
Disclosure based on the Financial Instruments and Exchange Act (Securities Report, QuarterlyReport, and Extraordinary Report) Disclosure based on the Companies Act (Notice ofConvocation of General Meeting of Shareholders, Business Report, Financial Statements andConsolidated Financial Statements)
ii. Timely Disclosure
Financial Report and related documents thereto: Information to be disclosed upon thedetermination or occurrence of a material fact (including information to be disclosed
voluntarily in addition to information to be disclosed in accordance with the Timely Disclosure
Rules of the Tokyo Stock Exchange)iii. Other Disclosure
Communication with analysts, institutional investors, credit rating agencies, and shareholders,etc. (disclosure of IR materials such as financial results briefings, individual interviews,

inquiries by telephone or e-mail, and financial results materials issued by the Company),
Integrated Report (Value Report), Business Report, and information on financial results ofsubsidiaries
4. Internal System for Information Disclosure
In order to make fair and transparent information disclosures, the Company will ensure that only
the employees in charge, head or officer of the division that is designated as the “Division in charge
for the information disclosure subject to this Policy” in the Company’s Regulations on the Divisionof Administrative Functions, and the President & Group CEO are involved in the communicationof the information to be disclosed. Any employee, director or officer of the Company or the Groupother than those who are designated as being responsible for information disclosure in theCompany’s Regulations on the Division of Administrative Functions must not, in principle,
communicate with any parties participating in capital markets in order to avoid the selective
disclosure of material information and to ensure consistency in the content of the disclosure.
5. Prohibition of Selective Disclosure
To prevent undisclosed material information from being selectively disclosed only to a limited
number of parties in capital markets, the Company will ensure that related persons to suchinformation, including the Company’s executives, strictly manage the information in accordancewith the internal rules.
6. Material Information
For the purpose of this Policy, "material information" means undisclosed information that may
affect stock or bond prices and influence investors' investment decisions. Typical examples ofmaterial information are as follows.
1. Securities Reports, Quarterly Reports, Extraordinary Reports and revised reports thereof as
required to be submitted under the Financial Instruments and Exchange Act;
2. Business reports and financial statements, etc. as required to be prepared under theCompanies Act;
3. Important corporate information such as the Financial Report required to be disclosed by
the Stock Exchange;
4. Quarterly financial results information and changes in forecasts;
5. Medium-term Management Plan;
6. Significant acquisitions, mergers, reorganizations (sale of business, liquidation, etc.),
acquisitions or disposals of significant assets;
7. Change of officers and management organization;

8. Damage resulting from disasters, damage arising in the course of business execution,
occurrence of material litigations, or other loss resulting from misconduct, etc.
7. Method of Information Disclosure
The Company will disclose information required to be disclosed under laws and regulations as wellas the Timely Disclosure Rules established by the Tokyo Stock Exchange in an appropriate manner,respectively, and will post the content of such information on its website as soon as possible after
disclosure. In addition, with regard to material information other than that required by laws andregulations, the Company will disclose it, as necessary, using appropriate methods, such as
distribution of news releases, holding press conferences and briefings, and posting on websites.
8. Quiet Period
The Company has a “quiet period” beginning from the day after the end of each quarter through theannouncement of the financial results for that quarter to prevent the leakage of material informationand to ensure fairness of disclosure. During this quiet period, the Company refrains from responding
to questions about the financial results or related inquiries.
9. Forecasts and Future Prospects
Among the information disclosed by the Company, forwardlooking information or statements, suchas future plans and forecasts, are prepared based on certain assumptions deemed reasonable at thetime of disclosure and involve risks and uncertainties. Therefore, the actual results announced later
may vary owing to various factors. In addition, the Company will, in principle, refrain fromcommenting on any third-party opinions, recommendations or performance forecasts regarding theCompany. However, if there is a significant misunderstanding or incorrect description on facts, theCompany may point it out.
November 22, 2021
MITSUI-SOKO HOLDINGS Co., Ltd.