Corporate Governance
Sun Frontier Fudousan Co., Ltd.
Last Updated: December 20, 2023
Sun Frontier Fudousan Co., Ltd.
Seiichi Saito, President Representative Director
Contact: Takeshi Hirahara, General Manager of Corporate Planning Division
Tel: 03-5521-1551
Securities Code: 8934
https://www.sunfrt.co.jp/

The status of the Company's corporate governance is as follows.
I. Basic Views on Corporate Governance, Capital Structure, Corporate Profile and Other Basic

Information
1. Basic Views
The Group’s basic policy for corporate management is that all officers and employees should set “the right thing to do asa human being” based on high ethical standards as a criterion for business execution and practice it.
Based on this, we recognize that it is an important mission of management to contribute to society through businessactivities and to pursue profit fairly, and to build firm trust from stakeholders such as shareholders, customers andemployees, business partners, partner companies, the environment, and local communities by continuously increasing
corporate value over the long term..
Based on this recognition, the Company is working to strengthen its corporate governance with the below basic policies:
（１）
（２）
（３）
（４）
（５）

improving transparency and ensuring fairness,
swift decision-making and business execution,
thorough accountability,
timely and appropriate information disclosure, andenhancement of compliance awareness.

At the 23rd Annual General Meeting of Shareholders Meeting held on June 21, 2022, the Company obtained approval forthe necessary Company's Articles of Incorporation change and made the transition from a company with Audit &Supervisory Board to a company with Audit & Supervisory Committee. By adopting this corporate governance system,
Audit & Supervisory Committee Members, who is in charge of audit and supervision of execution of duties of directors,
will become a member of the Board of Directors, thereby strengthening the supervisory function of the Board of
Directors and further enhancing corporate governance. In addition, by enabling Board of Directors to broadly delegate
decisions on business execution to directors, we aim to speed up decision-making on business execution. At the sametime, we aim to achieve sustainable growth and increase corporate value over the medium to long term by focusing onimportant management decisions such as management plans by Board of Directors.

[Reasons for Non-compliance with the Principles of the Corporate Governance Code][Supplementary Principle 4-1 (iii) Successor Plan]
Although the Group has not established a specific successor plan for the Representative Director, the Company aims tofoster successors by giving authority and responsibility to the General Managers and accumulating experience in a
climate of friendly competition.
[Supplementary Principle 4-3 (ii) and Supplementary Principle 4-3 (iii) Roles and Responsibilities of Board of Directors(3)]
Given that the appointment and dismissal of the Representative Director is the most important strategic decision making,the Board of Directors appoints a person who has excellent personality and insight, is well-respected, and has a wealth ofexperience after giving due consideration to the objectivity, timeliness, and transparency of the appointment procedures,and sufficient discussions within the Board of Directors.
[Supplementary Principle 4-10 (i) Voluntary Nomination and Compensation Committee]
As a voluntary advisory body of Board of Directors, in order to improve the objectivity and transparency of theprocedures concerning the appointment and dismissal of officers and the officers’ remuneration, the Company has
established a voluntary Nomination and Compensation Committee consisting of two or more members of ChairmanRepresentative Director, President-Representative Director and Outside Directors. For details, please refer to “II 1.
Organizational Composition and Operation [Voluntary Committee]” of this report. From now on, we will consider
making Outside Directors the majority of the members of the committee.

[Disclosure Based on the Principles of the Corporate Governance Code][Principle 1-4 Cross-shareholdings]
As a basic policy, the Group does not hold cross-shareholdings unless the significance of such holdings is fullyrecognized.
The case where the significance of holding is fully recognized is the case where it is judged to contribute to themaintenance and improvement of the Company's corporate value.
In the event that the Group holds cross-shareholdings, the Group shall exercise its voting rights after comprehensively
judging the pros and cons of such shareholdings, taking into consideration whether the issuing company has established
an appropriate governance system and makes appropriate decisions that will lead to an increase in corporate value overthe medium to long term, and from the perspective of improving the Company's corporate value.
If the Group judges that it cannot approve the proposal, the Group may consider the necessity of selling.
[Principle 1-7 Related Party Transactions]
In order to protect the interests of shareholders, the Group endeavors to prevent officers and employees of the Group
from engaging in transactions that are contrary to the interests of the Group and its shareholders.
The directors of the Company shall not pursue their own interests or the interests of third parties against the interests of
the Company, and even if they do not intend to do so, the supervisors shall not conduct conflict of interest transactions orcompetitive transactions without the approval of the Board of Directors. With regard to transactions between relatedparties, the relevant officers shall be excluded from the quorum of the resolution as specially interested parties, and theresolution shall be adopted in the Board of Directors. The Company shall verify after the fact that such transactions havebeen carried out properly and report this to the Board of Directors.
The Company also conducts quarterly investigations of all officers, including those of the Company and its subsidiaries,
to confirm whether there is any transaction between related parties.
【Supplementary Principle 2-4 (i) Ensuring Diversity in the Company, including the Promotion of Active Participation of
Women】The Group assigns employees to managerial positions based on performance and aptitude, regardless of gender,
nationality, or mid-career recruitment. The Company has set a target of raising the ratio of female managers to 12% ormore by April 2025. As of the end of March 2023, 8.8% of the Company's managers (section managers and above) were
women. For other indices related to diversity, please refer to “ ESG data (Social)” at the page of 36 in our sustainability
report 2023 (https://www.sunfrt.co.jp/en/pdf/sustainability_report_2023i_en.pdf) on the Company’s website.

In addition, “ Human Resource Development Policy” and “Internal Environment Development Policy” is at the page of
24 in our sustainability report (https://www.sunfrt.co.jp/en/pdf/sustainability_report_2023i_en.pdf) on the Company’s
website.
[Principle 2-6 Function as an asset owner of corporate pension]
The Company does not have a corporate pension system. When considering the adoption of a corporate pension system,
the Company will make personnel and management efforts so that the corporate pension can function as an asset owner,considering that the management of the reserve fund of the corporate pension will affect the stable asset formation of
employees and the financial condition of the Company.

[Principle 3-1 Enhancement of Information Disclosure]<Company objectives (Credo, mission, etc.) and management plans>
The Group's Company policy, Credo, mission and management plans are available on the Company's website.
・ Credo, mission and such https://www.sunfrt.co.jp/en/company/concept_comp.html
・ Medium-term management plan https://www.sunfrt.co.jp/en/ir_info/ir_prospects/
・ Sustainability https://www.sunfrt.co.jp/en/sustainability/<Basic views and basic policy on Corporate Governance>
Please refer to “I 1. Basic Views” of this report for the Group's basic views on corporate governance.

<Policies and procedures in determining the remuneration of directors who are not Audit & Supervisory Committee
members>
With respect to remuneration of directors, who are not Audit & Supervisory Committee members, the remuneration
amount and stock remuneration, which consist of a performance-linked portion and a fixed portion based on rank, aredetermined for internal director. With respect to outside director, the appropriate fixed remuneration amount isdetermined from the viewpoint of ensuring independence, based on the Board of Directors’ resolution, within theframework approved by the General Meeting of Shareholders. This decision was made by the Board of Directors after
consultation to the Nomination and Compensation Committee with two or more members from Chairman-Representative
Director, President-Representative Director and Outside Directors.
<Policies and Procedures for Nominating Candidates for Directors>
In selecting a director, the Group assumes that the following requirements are met, in addition to satisfying therequirements stipulated in laws and regulations and the Articles of Incorporation, not being applicable to reasons fordisqualification stipulated in the Regulations for Officers, and not having been involved with anti-social forces at present
and in the past（１）

Has empathy with the Company Policy, Management Principle, and Corporate Philosophy of the Group, and has
the intention to contribute to the progress and development of society through the Group’s business management（２） Has excellent personality, knowledge, and insight, and has a high law-abiding spirit and ethics（３） Has objective judgment capabilities, insight, and foresightIn addition to the preceding paragraph, the Company requires the following qualifications in selecting outside directors.
（１） Has a high level of insight, a wealth of practical experience, or experience of playing a leading role in any fieldsuch as corporate management, internal control, legal compliance, finance/accounting, finance, legal profession,
administration, crisis management, and education（２） Has the ability to understand the Group as a whole, the ability to understand essential issues and risks, and is
expected to contribute to frank, active, and constructive deliberations in the Board of Directors, etc.
（３） Has no direct interests with the Representative Director and directors, and is independent from the Company's
general shareholders without the risk of causing conflicts of interest with general shareholders
In addition, the Company has established the following requirements according to each position and role:
Outside directors shall be able to provide advice and support for the sustainable growth of the Company andobjective management supervision and judgment from a practical viewpoint based on a wealth of experience incorporate management and specialized fields（２） Full-time directors shall be familiar with the Group’s industry trends and related regulations and the Group’sbusiness model, and shall have abundant practical experience in their respective specialized fields
Also, they are appointed with the aim of further enhancing the neutrality and independency of the audit systemfrom a company-wide perspective（３） Outside directors, who is an Audit & Supervisory Committee Member, are able to express their opinions on audits
objectively from a neutral standpoint（４） As a full-time Audit & Supervisory Committee Member, the Director is well-versed in the organization, business,and business processes of the Company, appropriately collects information from within the Company, and iscapable of conducting highly effective audits（１）

The Board of Directors deliberates on proposals to be submitted to the annual general meeting of shareholders in light of
the above requirements, and appoints the appropriate persons as candidates for directors.
In addition, the Board of Directors will deliberate on proposals to be submitted to the annual general meeting ofshareholders in light of the above requirements, and if individual directors no longer meet the requirements or are likely
to fail to meet the requirements, they will not be selected as candidates for reappointment as directors at the end of theirterms of office.
<Explanation of Individual Election and Nominations>
The reasons for the election of candidates for director are disclosed in the annual general meeting of shareholders
convocation notice.
【Supplementary Principle 3-1 (iii) Initiatives for Sustainability】
The Group established the “Sustainability Committee” as an advisory body to the President Representative Director
with the aim of contributing to the realization of a sustainable society and increasing corporate value over the medium tolong term, through stronger promotion of activities that contribute to the resolution of social issues based on theManagement Principle and Corporate Philosophy. The Sustainability Committee meets four times a year on a regularbasis and as needed. In order to promote our sustainability activities, we disclose the information based on the TCFD
(Task Force on Climate-related Financial Disclosures) recommendations, which we support. Please refer to“Sustainability” https://www.sunfrt.co.jp/en/sustainability/ on the Company's website for information on the status of oursustainability activities.

[Supplementary Principle 4-1 (i) Scope of delegation to management]
In order to further strengthen the supervisory function of the Board of Directors and to speed up management decisionmaking, in June 2022 we made the transition to a Company with Audit & Supervisory Board Committee. With the
exception of matters specified by laws and regulations as matters to be determined exclusively by Board of Directors andimportant matters specified by the Board of Directors Regulations, Board of Directors delegates important businessexecution decisions to directors, thereby focusing on making important business basic policy decisions and supervisingbusiness execution.
[Principle 4-9 Independence Standards for an Independent Outside Director]
The Group has judged that the Independence Standards established by the Companies Act and the Tokyo Stock
Exchange are appropriate as the Group’s standards, and has selected candidates for independent outside directors basedon these standards.

[Supplementary Principle 4-11 (i) Preconditions for ensuring the effectiveness of the Board of Directors and Audit &Supervisory Committee]
When nominating candidates for directors and Audit & Supervisory Committee members, the Company selects a wide
range of candidates from both inside and outside the Company and elects candidates with excellent personality, insightand high management ability for the Board of Directors. In particular, independent outside directors are nominated frompersons who have abundant experience and knowledge in various fields and who are capable of fulfilling their roles andresponsibilities from a professional and objective viewpoint, such as providing advice to enhance corporate value overthe medium to long term and supervising management. The selection criteria for executive directors are that they arefamiliar with the Group’s industry trends and related regulations, the Group’s business model, and have a wealth ofpractical experience in their respective specialized fields.

Director's expertise and experience (skill matrix) are disclosed on the Company's website.
https://www.sunfrt.co.jp/en/sustainability/esg_governance.html
For policies and procedures regarding the election of directors, please refer to the above (Principle 3-1: Enhancement ofInformation Disclosure).

[Supplementary Principle 4-11 (ii) Concurrent Positions of Directors]
The status of concurrent positions of officers is disclosed in the notice of the Annual General Meeting of Shareholders.
[Supplementary Principle 4-11 (iii) Board of Directors Effectiveness Evaluation]
The Company analyzes and evaluates the effectiveness of the Board of Directors in order to improve the functions of theBoard of Directors. To be more specific, we conduct surveys targeting directors and Audit & Supervisory Committee
Members on general matters related to the Board of Directors, including the composition and operation methods of theBoard of Directors, the status of deliberations, and the status of support systems for directors and Audit & Supervisory
Committee Members. The results of these analyses are then evaluated by the Board of Directors. In order to obtain frankopinions from the survey subjects, we conduct an anonymous questionnaire survey and entrust the collection, tabulation
and analysis of the survey results to an external organization.
As a result of this year's survey, we have determined that the effectiveness of the Board of Directors has been largely
secured. In response to the survey results, issues from a medium- to long-term perspective were raised, such as “setting
KPIs that enable the Company to achieve sustainable growth” and “a system to periodically review the entire Group'sbusiness portfolio in consideration of securing sustainable profitability and the cost of capital.” Going forward, theCompany will strive to improve corporate governance through the resolution of issues identified in this evaluation, andfurther promote management aimed at sustainable enhancement of corporate value.
[Supplementary Principle 4-14 (ii) Director training policies]
Although the Company has not established the “Policy for Training for Directors” in a clear form, the Company has
stated as a part of Management Principle to “Contribute to the prosperity of mankind and society with a spirit ofsymbiosis.” For this reason, the Company provides ample training opportunities for officers and employees to acquire
the knowledge necessary to fulfill their roles and responsibilities, and bears the expenses for them.
The Company also holds seminars and participates in external seminars at the request of each officer.

[Principle 5-1 Policy for Constructive Dialogue with Shareholders]
The Group has the Corporate Planning Division as the department in charge of IR.
For shareholders and investors, the Company holds financial results briefings once every quarter, and also holds small
meetings, etc.
Moreover, the Company has established the following policy regarding constructive dialogue with shareholders so thatsuch dialogue will contribute to the sustainable growth of the Company and the improvement of corporate value over the
medium to long term.
（１）

We will disclose information to all stakeholders, including shareholders and investors, in a fair and timely manner,and place importance on direct communication by the Representative Director.
（２） The Corporate Planning Division will serve as the IR contact point and promote organic coordination with related
departments.
（３） Provide a wide range of means of dialogue, including financial results briefings, briefings for individual investors,
field tours, and small meetings.
（４） The Corporate Planning Division will report the status of the dialogue to the Representative Director and, if
necessary, to the Board of Directors.
（５） The Company shall establish rules for the prevention of insider trading and make them known to all employees.

[Action to Implement Management that is Conscious of Cost of Capital and Stock Price]
On December 20, 2023 we disclosed “Action to Implement Management that is Conscious of Cost of Capital and Stock
Price”. See the outline of the disclosure as below.
https://www.sunfrt.co.jp/en/pdf/20231220_en.pdf

Specific IR activities are disclosed in the IR presentation published for each quarter. Please refer to it at the link below.
https://www.sunfrt.co.jp/en/ir_info/

2. Capital Structure
Foreign Shareholding Ratio

From 10% to less than 20%[Status of Major Shareholders]Name/Company Name
HOUON Co.,Ltd
The Master Trust Bank of Japan, Ltd. (Accounted in trust)Tomoaki HORIGUCHI
Custody Bank of Japan, Ltd. (Accounted in trust)
SKAWAGOE Co., Ltd.
THE BANK OF NEW YORK MELLON 140044
MSIP CLIENT SECURITIESSTATE STREET BANK AND TRUST COMPANY 505223
Keiko Horiguchi
Sun Frontier Employee Stock Ownership Plan
Controlling Shareholder (except for--Parent Company)
Parent Company

Number of Shares
Owned
17,957,500
4,272,100
3,026,796
1,600,400
1,566,400
726,268
552,900
436,187
416,500
404,100

Percentage
(%)
36.89
8.78
6.22
3.29
3.22
1.49
1.14
0.90
0.86
0.83

None

Supplementary Explanation
The status of major shareholders is as of September 30, 2023. In addition to the above, the Company holds 73,752
treasury shares.

3. Company Attributes
Listed Stock Market and Market
SectionTokyo Prime

Fiscal Year-End

MarchType of Business

Real Estate

Number of Employees(consolidated) as of the End of thePrevious Fiscal YearSales (consolidated) as of the Endof the Previous Fiscal Year
Number of Consolidated
Subsidiaries as of the End of thePrevious Fiscal Year

500 or more and less than 1,000
From JPY10 billion to less than JPY100 billion
From 10 to less than 50

4. Policy on Measures to Protect Minority Shareholders in Conducting Transactions with Controlling
Shareholder-----------

5. Other Special Circumstances which may have Material Impact on Corporate Governance-----------

II. Business Management Organization and Other Corporate Governance Systems regarding Decisionmaking, Execution of Business, and Oversight in Management
1. Organizational Composition and Operation
Organization Form

Company with Audit & Supervisory Committee[Directors]
Maximum Number of Directors
Stipulated in Articles ofIncorporation
Term of Office Stipulated in Articles
of Incorporation

14 people
1 yearChairperson of the Board

President

Number of Directors

11 people

Status of appointing Outside
Director

Appointed

Number of Outside Directors

4 people

Number of Outside Directors
designated as independent officers

4 people

Outside Directors’ Relationship with the Company (1)NameAttributeaKazutaka Okubo

CPA

Keiichi Asai

From anothercompany
CPA

Hidetaka Tanaka
Tsuneko Murata

From anothercompanybcRelationshipwith theCompany *d e f g

h
〇

i

j

k

* Categories for “Relationship with the Company”* “○” when the director presently falls or has recently fallen under the category;“△” when the director fell under the category in the past
* “●” when a close relative of the director presently falls or has recently fallen under the category;“▲” when a close relative of the director fell under the category in the pasta. Executive of the listed company or its subsidiaries
b. Non-executive director or executive director of a parent company of the listed company
c. Executive of a fellow subsidiary company of the listed company
d. A party whose major client or supplier is the listed company or an executive thereof
e. Major client or supplier of the listed company or an executive thereof
f. Consultant, accountant or legal professional who receives a large amount of monetary consideration or other property
from the listed company besides compensation as a director/Audit & Supervisory Board member
g. Major shareholder of the listed company (or an executive of the said major shareholder if the shareholder is a legal
entity)h. Executive of a client or supplier company of the listed company (which does not correspond to any of d, e, or f) (thedirector himself/herself only)
i. Executive of a company, between which and the listed company outside directors/Audit & Supervisory Board
member are mutually appointed (the director himself/herself only)
j. Executive of a company or organization that receives a donation from the listed company (the director himself/herself
only)
k. Others

Outside Directors’ Relationship with the Company (2)Name

Kazutaka Okubo

Audit & Designation
Supplementary Explanation
SupervisoryasofCommittee Independent
the Relationship
MemberDirector〇

Reasons of Appointment

He has extensive knowledge andexperience in a wide range offields, including corporate
compliance and corporate social
responsibility, in addition to being
familiar with governance andfinance from his audit experienceat a major audit corporation. The
Mr. Kazutaka Okubo serves as
Company expects him to provide
President Representative
management supervision and
Director of SS DNAFORM,
advice based on his extensive
which is a business partner ofknowledge and experience, andthe Company. However, thehe has actively provided advice
net sales of the transaction isand recommendations to theinsignificant at less than 0.1%
Board of Directors. The Company
in terms of both therequests his re-election as Outside
Company's consolidated net
Director with the expectation thatsales and the net sales of SS
he will supervise the management
DNAFORM in the mostof the Company toward therecent fiscal year, and thesustainable improvement of theCompany has determined that
corporate value of the Company.
there is no risk of affecting his
In addition, there are no attributes
independence.
that would raise questions about
his independence from theCompany. Therefore, theCompany has judged that there isno risk of conflict of interest withgeneral shareholders and has
nominated him as an independent
officer.

Keiichi Asai

Hidetaka Tanaka

〇

〇

---

〇

---

After joining Mitsubishi
Corporation, he gained
experience in oil businessdivisions such as oil sales, supply
and demand, and refining. He
worked in the United States andIndia, and in almost every
instance was involved ininternational business in theenergy sector. Since assuming theposts of Vice President Directorof Lithium Energy Japan Co., Ltd.
in 2013 and President
Representative Director of KH
Neochem Co.,Ltd. in 2014, he has
been involved in general
corporate management and has
extensive knowledge andexperience.
The Company has judged that hecan be expected to supervise themanagement of the Company andperform his duties appropriately
based on his abundant knowledge
and experience and requests that
he be re-elected as Outside
Director. In addition, there are no
attributes that would raisequestions about his independence
from the Company. Therefore, theCompany has judged that there isno risk of conflict of interest withgeneral shareholders and has
nominated him as an independent
officer.
He is qualified as a Certified
Public Accountant of the UnitedStates and has a wealth ofexperience as a corporate
manager and has businessexperience overseas. He has awide range of knowledge
including a thorough knowledgeof the financial industry and thefield of sustainability. Based on
his wealth of experience andknowledge, etc., the Company
elected him as an Outside
Director so that he can audit andsupervise the Company from an
objective standpoint with regard
to the overall management of theCompany, including thepromotion of sustainability. Basedon his attributes and relationshipwith the Company, the Company
has determined that there is norisk of conflict of interest withgeneral shareholders anddesignated him as an independent
officer as stipulated by the Tokyo
Stock Exchange.

Tsuneko Murata〇〇

She has experience as a managerof the legal division of thePanasonic Group and as a board
member and auditor of the Japan
Pension Service, as well as acareer in Outside Officer at alisted company. She has a wealthof knowledge related to legal
affairs, management and audit. In
addition, she has a wide range ofknowledge in promoting theactive participation of women.
Based on this insight, theCompany expects that she will
make active proposals forstrengthening corporate
governance, deliberating
important management matters in
the Board of Directors,
monitoring management, andpromoting sustainability, andproposes her election as an
Outside Director. In addition,
there are no attributes that would
raise questions about her
independence from the Company.
Therefore, the Company has
judged that there is no risk of
conflict of interest with generalshareholders and has nominatedher as an independent officer.

---

Audit & Supervisory Committee
Composition of Members and Attributes of Chairperson
All Committee
Members

Full-timeMemberInside Director

OutsideDirectors

Chairperson

Audit &
Supervisory
3 people
1 person1 person
2 people Inside Director
Committee
Whether there is a director or an
employee who is to assist the duties
Presentof the Audit & Supervisory
Committee
Matters related to the independency of the director and employees from the director in which the execution of businessis carried out
In the event that the Audit & Supervisory Committee requests the assignment of employees to assist with their duties,
employees shall be assigned to the Audit & Supervisory Committee. The Audit & Supervisory Committee’s assistantshall be appointed from among persons with sufficient knowledge of accounting or law, etc., and shall perform his/herduties in accordance with the instructions of the Audit & Supervisory Committee.

Coordination Situation of Audit & Supervisory Committee, Accounting Auditor and Internal Audit Divisions
Based on the Internal audit Plan, the Internal Audit Office conducts Internal audit regarding the operational status ofbusiness activities, the effectiveness and accuracy of business execution, the status of compliance, etc., and regularly
reports the audit results to the President-Representative Director and the Audit & Supervisory Committee, and also to theBoard of Directors as necessary. In addition, the Internal Audit Office explains the purpose of internal controls andevaluation of controls, and provides specific advice and recommendations for business improvement and appropriate
management.

Internal Audit Office, Audit & Supervisory Committee and Accounting Auditor closely coordinate with each other, andAudit & Supervisory Committee and Accounting Auditor have a system in which the Internal audit situation can be
grasped in a timely manner, and coordination is established between the Audit & Supervisory Committee audit andaccounting audit by exchanging information also.

[Voluntary Committee]
Voluntary Establishment ofCommittee(s) Corresponding to
Established
Nomination Committee orRemuneration Committee
Committee’s Name, Composition, and Attributes of Chairperson

Committee
Corresponding
to Nomination
Committee

Committee’s
Name

All
Full-time Inside Outside Outside
Committee Members Directors Directors Experts
Members

Nomination andCompensation
Committee

4 people0 people2 people2 people0 people 0 people

InsideDirector

4 people0 people2 people2 people0 people 0 people

InsideDirector

Committee
Corresponding Nomination andtoCompensation
Remuneration Committee
Committee
Supplementary Explanation

Chairperson
Other

In order to improve the objectivity and transparency of procedures related to the appointment and dismissal of directors
as well as renumeration, the Company has established a voluntary Nomination and Compensation Committee consistingof the Chairman-Representative Director and President-Representative Director as well as 2 or more outside directors inorder to ensure the objectivity and transparency of the procedures for determining remuneration for directors asvoluntary advisory body of the Board of Directors. The Nomination and Compensation Committee considers anddeliberates on standards, processes, basic policy of evaluation, etc. concerning officers' appointment and dismissal andofficers' remuneration, and the Board of Directors makes officers' appointment and dismissal and officers' remuneration
decisions with maximum respect for the deliberation contents.

[Independent Directors]
Number of Independent Directors

4 people

Matters relating to Independent Directors
All outside directors who satisfy the qualifications of independent directors are designated as independent directors.

[Incentives]
Incentive Policies for Directors

Performance-linked remuneration system, stock options, others

Supplementary Explanation
The Group grants executive officer awards to each director for the purpose of enhancing motivation and morale toimprove business performance by linking the improvement of the Group’s business performance with the profit of theGroup’s directors.
In addition, as part of the review of the officers’ remuneration system, directors (excluding outside directors), who are
not Audit & Supervisory Committee members, was approved at the 23rd Annual General Meeting of Shareholders
Meeting held on June 21, 2022 to introduce a new restricted stock remuneration system in place of the existing stock
remuneration stock option system, in order to share the benefits and risks of stock price fluctuations with shareholders
and to increase their willingness to contribute to higher stock prices and higher corporate value.

・ The total amount of cash remuneration claims to be provided as remuneration, etc. regarding Restricted Stock shall not
exceed 36 million yen per year.
・ The total number of shares with restriction on transfer to be allotted shall not exceed 50,000 shares per year.
For details, please refer to the news release “Notice Concerning Introduction of Restricted Stock remuneration System”
dated May 13, 2022.
It is available on our website at News Release (https://www.sunfrt.co.jp/en/pdf/20220513_7_en.pdf)
Recipients of Stock Options

Inside Directors

Supplementary Explanation
Directors of the Company (excluding outside directors) are eligible.
As described above, with the approval at the 23rd Annual General Meeting of Shareholders meeting held on June 21,2022, the Company has introduced a restricted stock remuneration plan in place of the stock remuneration type stock
option plan.

[Director Remuneration]
Disclosure of Individual Directors’
Remuneration
Supplementary Explanation

No Individual Disclosure

The remuneration for Directors of Sun Frontier Fudousan Co., Ltd. in fiscal 2022 (from April 1, 2022 to March 31, 2023)
was as follows.
・Six Directors other than Audit & Supervisory Committee Members (excluding Outside Directors):
Total amount of remuneration, etc.: 243 million yen (including basic remuneration: 158 million yen, performancelinked remuneration: 65 million yen, renumeration of restricted stock: 20 million yen)・One Audit & Supervisory Committee Member Director (excluding Outside Directors)
Total amount of remuneration: 9 million yen (including basic remuneration: 9 million yen)・One Audit & Supervisory Board Member (excluding outside auditors)
Total amount of remuneration: 2 million yen (including basic remuneration: 2 million yen)・Six Outside Officers
Total amount of remuneration: 25 million yen (including basic remuneration: 25 million yen)
Policy on Determining
Remuneration Amounts andEstablishedCalculation Methods
Disclosure of Policy on Determining Remuneration Amounts and Calculation Methods
1. Matters Related to Policies for Determining Details of remuneration, etc. of Director
The Company has established policies for determining the content of remuneration of Directors, who are not Audit &Supervisory Committee Member, as follows.
Fixed remuneration shall be an amount considered to be at an appropriate level in comparison with the performanceof other companies in the real estate industry in Japan, etc., in consideration of the content of duties and theCompany's situation, etc.
（２） Performance-linked remuneration shall be determined from the perspective of reflecting the results of the
improvement in performance by taking into consideration the status of achievement against the consolidated
performance ordinary profit (loss) based on the consolidated performance forecast during the relevant fiscal year.
（３） Directors (excluding outside directors) who are not Audit & Supervisory Committee Member shall be granted shareacquisition rights as share-based compensation stock options to share the benefits and risks of stock pricefluctuations with shareholders and to enhance the incentive effect of Directors to improve corporate performanceand the management awareness of shareholders.
（４） With regard to the ratio of individual remuneration, etc. for Directors who are not Audit & Supervisory Committee
Members (excluding Outside Directors) if the target indicator for the performance-linked remuneration is 100%
achieved, fixed remuneration will be 60%, performance-linked remuneration will be 30%, and share-based
compensation will be 10%. With regard to Outside Directors, only fixed remuneration and performance-linked
remuneration will be provided, but the above target will be referred to. (Revised on May 12, 2023. Prior torevision: fixed remuneration 65%, performance-linked remuneration 30%, restricted shares remuneration system
5%).
（１）

Matters concerning delegation pertaining to determination of contents of remuneration, etc. for individual Directors
who are not Audit & Supervisory Committee Members
The amount of fixed remuneration and performance-linked remuneration for each individual or the determinationof the methods for calculating such amounts shall be determined by resolution at the Board of Directors andentrusted to the Chairman-Representative Director.
In order to improve the objectivity and transparency of the procedures for determining renumeration of Directors,
the Company has established a Nomination and Compensation Committee consisting of the ChairmanRepresentative Director and President-Representative Director as well as 2 or more Outside Directors as avoluntary advisory body. The Nomination and Compensation Committee considers and deliberates on the amountof remuneration for Directors, the calculation method, the composition of remuneration, the ratio, and the setting ofindicators, and the Chairman-Representative Director makes decisions with maximum respect for the deliberation
contents.
（６） Status of the above decision policy for the fiscal year under review
The target for performance (consolidated ordinary profit (loss)), which is an indicator of performance-linked
compensation for the fiscal year under review, was 12,800 million yen, while the actual performance was 14,722
million yen. With regard to the amount of fixed renumeration and performance-linked renumeration for eachindividual or the determination of the methods for calculating such amounts, the Board of Directors involves theNomination and Compensation Committee and entrust the Chairman-Representative Director, who are able toevaluate each Director’s business. The Board of Directors received a report from the Nomination and Compensation
Committee, and determined that the content of individual compensation for Directors for the fiscal year under review,
including the procedure and content of the decision by the Chairman-Representative Director is consistent with theabove decision policy.
（５）

2. Matters concerning the remuneration of directors concerning the resolution of the General Meeting of Shareholders
Regarding the total amount of remuneration, etc. in directors other than Audit & Supervisory Committee members, it wasapproved at the 23rd Annual General Meeting of Shareholders held on June 21, 2022 that the following amount shall be
the upper limit. In addition, as a separate framework from (1), the Company has obtained approval to provide the stock
remuneration described in (2), excluding outside directors.
(1) Up to 360 million yen per year (including up to 36 million yen per year for outside directors)(2) The total amount of cash remuneration claims to be provided as remuneration stock (remuneration for Restricted
Shares, etc.) shall not exceed 36 million yen per year.
The maximum number of Restricted Shares to be allotted in each fiscal year shall be 50,000 shares. At the end of theAnnual General Meeting of Shareholders, the number of directors who are not Audit & Supervisory Committee
members was 8, and 6 excluding outside directors.
Regarding the total amount of remuneration of directors, who are Audit & Supervisory Committee members, wasapproved at the 23rd Annual General Meeting of Shareholders held on June 21, 2022 that the total amount should notexceed 36 million yen per year. At the end of this Annual General Meeting of Shareholders, the number of directors, who
are Audit & Supervisory Committee members, was 3.
3. Matters concerning the determination of the content of remuneration, etc., for each individual directors who are not
Audit & Supervisory Committee member
With regard to the amount of remuneration, etc. of the Company's directors or the method of calculation, the Company
has established a voluntary Nomination and Compensation Committee consisting of two or more members from
Chairman-Representative Director, President-Representative Director and Outside Director in order to achieve
remuneration determination and improve the objectivity and transparency of the procedure. The ChairmanRepresentative Director has the authority to make a draft of the calculation method of the amount of remuneration, etc.,of the Company's directors and the basic policy. In the Nomination and Compensation Committee, based on the draft, thecomposition of remuneration, etc., of directors, its ratio, and the calculation method for setting indicators, etc., arediscussed. The Board of Directors has the authority to decide policies related to the determination of the amount of
remuneration, etc. of the Company's directors or the calculation method thereof. However, the Board of Directors will
decide the amount of remuneration, etc. of the Company's directors or the calculation method thereof by giving
maximum consideration to the content of deliberations by the Nomination and Compensation Committee..

[Supporting System for Outside Directors]
Although we do not have full-time employees related to Outside Directors, Corporate Planning Division provides
support as necessary.

2. Matters on Functions of Business Execution, Auditing, Oversight, Nomination and Remuneration Decisions(Overview of Current Corporate Governance System)
We are a company with Audit & Supervisory Committee. We have a Board of Directors consisting of 11 directors(including 4 outside directors) and an Audit & Supervisory Committee consisting of 3 directors who are Audit &Supervisory Committee members (including 2 outside directors).
With regard to the appointment/dismissal of director and remuneration, etc., the Company has established theNomination and Compensation Committee, which consists of Chairman-Representative Director, PresidentRepresentative Director and two independent outside directors, and has ensured the objectivity and transparency of theprocedures by conducting consultation in the said committee.
With regard to accounting audits, the Company has entered into an audit agreement with BDO Sanyu and the Company
conducts accounting audits throughout the fiscal year without focusing on year-end audits. The Company has establisheda system that enables appropriate handling of accounting issues, and has enhanced the effectiveness of audits throughclose cooperation with the Audit & Supervisory Committee members of the Company and the Internal Audit Office.
The current auditing organization is as follows.
・ BDO Sanyu
Hitoshi Torii, Designated Partner and Engagement Partner
Tomoharu Takahashi, Designated Partner and Engagement Partner
・ Assistant for Accounting Audit Services
Six CPAs and three other members

3. Reasons for Adoption of Current Corporate Governance System
To further enhance its corporate governance and increase its corporate value, the Company shifted to a corporate
governance system with an Audit & Supervisory Committee in June 2022.The Company will further enhance its
corporate governance and increase its corporate value by shifting to a corporate governance system with Audit &Supervisory Committee. Furthermore, by inviting more than one outside director and establishing a voluntary
Nomination and Compensation Committee, we aim to strengthen the Board of Directors’ supervisory functions andrealize fair and transparent management.

III. Implementation of Measures for Shareholders and Other Stakeholders
1. Measures to Vitalize the General Shareholder Meetings and Smooth Exercise of Voting Rights
Supplementary explanations
Early Notification of General
Shareholder Meeting
Exercise of Voting Rights by
Electromagnetic Means
Participation in the Electronic
Voting Platform and other initiatives
to improve the environment for
institutional investors to exercise
their voting rights
Providing Convocation Notice inEnglish (short form)
Other

In order for shareholders to fully consider and deepen their understandingof the proposals, we have sent them by three weeks prior to the annual
general meeting of shareholders.
You can exercise your voting rights via the Internet.

The Company participates in the Electronic Voting Platform.

We have translated and prepared an English version.
The Notice of the General Meeting of Shareholders (including English
translation) is posted on the Company's website.

2. IR Activities

Supplementary Explanations

Directexplanationfrom theRepresentative
Director

Regular Investor Briefings for
Individual Investors

The Company holds briefings for individual investors atleast once a year to increase the number of shareholders
who can support the Company over the long term.

Yes

Regular Investor Briefings forAnalysts and Institutional
Investors

At least once every quarter, we hold company briefings
for analysts and institutional investors.

Yes

Posting of IR Materials on
WebsiteEstablishment of Department
and/or Manager in Charge of IR

The IR materials used in the above-mentioned company
briefing sessions are posted on the Company's website,
and the scenes of the briefing sessions on the day can beviewed in an on-demand format.
The Company's IR Division is as follows.
・ Division in charge: Corporate Planning Division
・ Tel: 03-5521-1551

3. Measures to Ensure Due Respect for Stakeholders

Implementation of Environmental
Activities, CSR Activities etc.

Supplementary explanations
With the Company’s designated Credo “altruism,” and its mission “protect all
employees, pursue the material and intellectual happiness, with the heart ofcoexistence we contribute to the prosperity of society and humankind” we areworking to resolve environmental and social issues as our business grows.
In line with our vision “Our vision is to become the most appreciatedvisionary company that fully utilizes limited resources and continues thechallenges to create new values” we will focus even more on businesses that
contribute to the resolution of environmental issues.
Please refer to https://www.sunfrt.co.jp/en/sustainability/ for more
information on our sustainability activities.

IV. Matters Related to the Internal Control System
1. Basic Views on Internal Control System and the Progress of System Development
In accordance with the Ordinance for Enforcement of Companies Act of Japan and Companies Act of Japan, theCompany resolution “Internal Control System Construction basic policy” in Board of Directors as described below, andhas established and is operating its system.
(1) Systems to Ensure That Directors and Employees Execute Their Duties in Compliance with Laws and Regulations
and the Articles of Incorporation
The Company recognizes that it is its corporate social responsibility to ensure that all directors and employees, basedon a fair and high sense of ethics, always realize the spirit of legal compliance and execute business operations. The
Company is working to strengthen its internal management system, raise awareness of compliance, and establish amanagement system that will continue to be trusted by society in the future.
To be more specific, we have established the Internal Audit Office, which is under direct control of PresidentRepresentative Director, to conduct regular internal audits of all departments and group companies without
exception. In the internal audit, the Company ascertains the status and structure of business operations, and fairly
investigates and verifies whether all business operations are conducted properly in accordance with laws andregulations, the Articles of Incorporation, and internal rules, as well as whether corporate systems, organizations, andrules are appropriate and proper, and reports the audit results to the President-Representative Director and the Audit& Supervisory Committee regularly, as well as reporting to Board of Directors as necessary. In addition, theCompany has established a “Corporate Ethics Help Line” for the prevention and early detection of misconduct due toviolations of laws and regulations and misconduct, improvement of the mobility of the self-purification process,control of reputational risk, and assurance of social trust. The Company has also established a thorough whistleblowing system that protects whistle-blowers. Furthermore, in order to improve compliance awareness, the Legal
Affairs Department has been established and various types of training and education are conducted. The Company
and its group companies have no involvement with anti-social forces and respond firmly to unreasonable demands.
(2) Systems for the Preservation and Management of Information Concerning the Execution of Duties by Directors
The Company properly records information concerning the execution of duties by directors, such as records
concerning the decision-making at important meetings, including the Board of Directors meetings, and documents
approved by each director based on the “Regulations on Authority of Duties.” The Company also retains such

information for a specified period of time based on laws and regulations and the “Document Handling Regulations,”
etc., and maintains a condition in which directors can inspect it as necessary. In addition, the General Manager of theManagement Division is responsible for supervising the preservation and management of information.
(3) Regulations on Risk Management and Other Systems for Risk Management
In order to cope with all risks that threaten the improvement of corporate value and sustainable development, a risk
management manual, etc. shall be prepared, and in the event of an unexpected situation, a response headquarters(including the formation of a team of outside experts such as corporate lawyers) headed by the PresidentRepresentative Director shall be established.
(4) Systems to Ensure Efficient Execution of Duties by Directors
The Board of Directors formulates medium-term management policies and single-year management plans as
indicators to establish and implement the corporate vision of the Company as a whole. In order to realize thesemanagement policies and management plans, the Board of Directors clarifies the executive authority of directors andthe duties in charge, thereby enhancing the efficiency of execution of duties.
In addition, with regard to matters for which decisions on business execution have been delegated to PresidentRepresentative Director and other directors who are in charge of business execution, the Company makes necessary
decisions based on the “Organization Rules” or the “Management Rules for Affiliated Companies” including groupcompanies.
The Company will revise these rules as appropriate in light of revisions and abolition of laws and regulations and forthe purpose of improving the efficiency of the execution of duties.
(5) Systems to Ensure the Appropriateness of Business Operations in our Company as well as Corporate Group
Consisting of Group Companies
In order to ensure the appropriate execution of business operations by group companies, the Corporate Planning
Division shall have jurisdiction over the management of group companies in accordance with the “Regulations forManagement of Affiliated Companies. While respecting the autonomy of group companies, the Corporate Planning
Division shall receive periodic reports on the status of business operations, including matters related to the executionof director duties of Group companies, and shall require prior consultation or approval with the Company with regard
to important matters concerning the management of group companies. The management plans of the groupcompanies are also formulated under the management of the Company, and the Company provides timely andappropriate advice and guidance during the business period to improve the efficiency of the operations of the groupcompanies. In addition, the Company and group companies have established the Risk Management Committee,
which is chaired by the President-Representative Director, and a person responsible for risk management is assigned
to each department. Any management or business risks that may arise are reported to the Risk Management
Committee, where risk information is analyzed and countermeasures are considered to prevent or minimize damage
to the Company and its group companies. The Company has established a system under which violations of laws andregulations or illegal acts that occur or are likely to occur at group companies are reported to internal reporting
offices or outside directors who are Audit & Supervisory Committee members as stipulated in the “Corporate Ethics
Helpline Regulations, and is working to detect and resolve such violations at an early stage. The Internal Audit
Office of the Company conducts internal audits of all group companies in order to ensure the effectiveness andappropriateness of systems, organizations, and rules for the overall operations of the group companies, and reports
the results to the Company's President-Representative Director and designated organizations such as the Audit &Supervisory Committee. The Company’s President-Representative Director prepares and reports its financial
statements in accordance with fair and appropriate accounting standards in order to enhance the reliability of its
financial reporting and enhance its corporate value.
(6) Matters concerning Employees who assist the Audit & Supervisory Committee in their Duties
If the Audit & Supervisory Committee request an employee to assist the Audit & Supervisory Committee in theirduties, the Company appoints employees as the Audit & Supervisory Committee’s assistant. The Audit &Supervisory Committee’s assistant is appointed from persons who have sufficient knowledge of accounting or law,etc., and perform their duties in accordance with the instructions of the Audit & Supervisory Committee.
(7) Independence of Employees from Directors
In order to ensure the independence of the Audit & Supervisory Committee’s assistant as set forth in the preceding
paragraph, the Company has decided to report personnel changes and personnel of the said employee to the Audit &Supervisory Committee in advance and obtain their consent.
(8) Matters concerning Assurance of Effectiveness of Instructions to the Employee who is designated to be the Audit &Supervisory Committee’s assistant in (6)The Audit & Supervisory Committee’s assistants in (6) are ensured the opportunity to attend important meetings ofthe Board of Directors and other meetings accompanying the Audit & Supervisory Committee. In addition, the Audit& Supervisory Committee’s assistant accompany the Audit & Supervisory Committee to regularly exchange
opinions with the President-Representative Director and the Accounting Auditor. With regard to instructions fromthe Audit & Supervisory Committee, directors and employees cooperate in the development of an audit environment
so that the Audit & Supervisory Committee’s assistant’s work is carried out smoothly.
(9) System for Reporting to the Company’s Audit & Supervisory Committee by Directors and Employees of theCompany and Group Companies and System for Reporting to other Audit & Supervisory Committees

All directors (excluding directors who are Audit & Supervisory Committee members) and General Managers ofDepartments of the Company shall report on the status of execution of the duties of which he/she is in charge inmeetings attended by Board of Directors and other Audit & Supervisory Committee members and shall be allowed toattend any meetings within the Company if requested by the Audit & Supervisory Committee.
Directors (excluding directors who are Audit & Supervisory Committee members) and employees of the Company aswell as directors, auditors, and employees of group companies (hereinafter referred to as “directors and employees of
the Company and its group companies”) immediately report to the Audit & Supervisory Committee as soon as they
discover any matter that may or may have a material impact on the Company's credit, business performance, etc., or
any material violation of the Corporate Vision, Corporate Behavior Rules, etc.
Directors and employees of the Company and its group companies may report to the Internal Reporting Office of theCompany as set forth in the “Corporate Ethics Corporate Ethics Help Line” at any time, and in addition, they canreport voluntarily to the Company’s Audit & Supervisory Committee member.
The Compliance Division of the Company encourages the directors and employees to familiarize themselves with thecontact points for reporting and actively report through educational and training opportunities. The “Rules
Concerning the Corporate Ethics Help Line” clearly stipulate directors and employees of the Company and its groupcompanies will not be subjected to disadvantageous treatment in personnel evaluation and will not be subject toadverse dispositions such as disciplinary action by reporting to the Whistleblower Hotline. In addition, the Company
makes it known to the public that they will not be subject to adverse dispositions on the grounds that they havereported to the Audit & Supervisory Committee.
(10) Matters concerning the Policy for the Disposition of Expenses or Liabilities Incurred in the Execution of Duties by
Audit & Supervisory Committee Members (limited to those related to the execution of Audit & Supervisory
Committee duties)
When Audit & Supervisory Committee members request advance payment of expenses incurred in the execution of
their duties, reimbursement of expenses paid, etc., or performance of liabilities incurred, the Company promptly
responds thereto, except in cases where it can be proven that such expenses, etc. have not arisen in the execution ofduties by Audit & Supervisory Committee members or the execution of Audit & Supervisory Committee duties.
(11) Others, System to Ensure Effective Audits by the Audit & Supervisory Committee
President-Representative Director holds regular meetings with Audit & Supervisory Committee members for mutualcommunication.
In addition, in accordance with the “Regulations for Internal Audit” and the “Internal Audit Implementation
Guidelines,” the Internal Audit Office will closely communicate and coordinate with the Audit & Supervisory
Committee and the outside auditors in order for them to efficiently and effectively conduct audits.

2. Basic Views on Eliminating Anti-Social Forces(1) Establishment of Response Control Department and Person in Charge of Prevention of Unreasonable Demands
The Company has established a Person in Charge of Control and Person in Charge of Response as a system against
anti-social forces. The Company has established a system that enables it to respond in an organized manner bycontacting and consulting with the General Manager and the Response Manager without taking any personal
response in the event of an unjust act or request.
(2) Cooperation with External Specialized Agencies
The Company has established a system against anti-social forces in cooperation with competent police stations andexternal experts such as corporate lawyers. In addition, the Company is a member of the Special Violence Prevention
Association under the Metropolitan Police Department (Tokubouren) and actively participates in activities toeliminate organized crime groups.
(3) Status of Aggregation and Management of Information on Anti-Social Forces
The Compliance Division gathers and manages information on anti-social forces in order to prevent damage fromanti-social forces by judging the attributes of business partners.
(4) Preparation of Response Manuals
The Company has prepared the Anti-Social Forces Response Manual, which sets standards of conduct for anti-social
forces. All officers and employees of the group view the manual on the Company's LAN.
(5) Status of Implementation of Training Activities
In the training by the Compliance Department, the Company strives to ensure that officers and employees arethoroughly educated and informed.

V. Other
1. Adoption of Anti-Takeover Measures
Adoption of Anti-Takeover
Not Adopted
Measures
Supplementary Explanation

2. Other Matters Concerning the Corporate Governance System
Overview of Timely Disclosure System
The status of the Company's internal system for timely disclosure of corporate information is as follows.
1. Basic Stance on Timely Disclosure
From the perspective of corporate social responsibility and medium- to long-term enhancement of corporate value,
the Company is committed to fulfilling its responsibilities to all stakeholders including shareholders and investors.
We will disclose information in a timely, accurate and fair manner. In addition, Companies Act of Japan, theFinancial Instruments and Exchange Act, various laws and regulations as well as the rules set by the stock exchanges(hereinafter referred to as “laws and regulations.”) In addition to promptly disclosing information that falls under the“Securities Listing Regulations”, we will also actively disclose socially useful information about the Group.
2. Status of Internal System for Timely Disclosure
The Company has established a system under which important corporate information, including information related
to subsidiaries, is centrally managed under the Corporate Planning Division, which is in charge of timely disclosureof information.
Corporate Planning Division makes the determination as to whether or not the information falls under the category oftimely disclosure information in accordance with the TSE's Securities Listing Regulations, and with the approval of
the President-Representative Director (or in the absence of Representative Director, officers and employees who havenotified the TSE and other Tokyo Stock Exchanges as the person responsible for handling information of theCompany), decides on the content, timing and method of the disclosure.
Based on this decision, information disclosure is, in principle, carried out by the Representative Director or a person
delegated by the Representative Director, and managed by the Corporate Planning Division.
Information is made public by registering with TDnet and, if necessary, by holding press conferences and postingmaterials.
All information registered in TDnet is also posted on the Company's website.
In addition, the Company discloses information in accordance with various laws and regulations as well as internal
rules such as the rules for preventing insider trading.
The system for collecting important corporate information for the Corporate Planning Division is as follows.
Corporate Planning Division is aware of all proposals to be proposed and reported to the Board of Directors and the
Executive Officer Committee.
(1) Decision madeAt the Company, important matters that fall under a decision made are decided by the Board of Directors.
Accordingly, Corporate Planning Division is fully aware of the decisions made.
(2) Occurrence of Material Facts
When officers and employees of the Company learn that a Material Fact has occurred or is likely to occur, they are
obliged to promptly notify the Corporate Planning Division of the details thereof.
(3) Financial Results
With regard to financial information, the accounting department prepares the Financial Statements, etc., and at thesame time receives audit by the Accounting Auditor. Financial results, including analysis of major items, aresubmitted to the Board of Directors.
Moreover, audit by the Accounting Auditor is implemented during the fiscal year to reduce the impact at the end of
the fiscal year.
As a result, the Company strives to disclose information accurately and promptly.
(4) Information on subsidiaries
Officers and employees of the Company in charge of subsidiaries and officers and employees of subsidiaries are
required to contact Corporate Planning Division when they learn that a Material Fact has occurred or may haveoccurred to subsidiaries.