[Reference]
Response of Listed Companies
regarding Revised Corporate
Governance Code(As of December 31, 2021)
Tokyo Stock Exchange, Inc.
January 26, 2022

*This English translation is for reference purpose only.

IntroductionThis report provides information on the status of efforts to implement the principles of the Corporate Governance Coderevised in June 2021(hereinafter referred to as “Code”), based on the "Reports on Corporate Governance" (hereinafterreferred to as "Governance Reports") submitted by listed companies by the end of December 2021.

The Code adopts a "comply or explain" approach. If there is a principle that is not appropriate to implement in light ofeach company’s unique circumstances, the company will provide explanation of the reasons for not implementing theprinciple.

It should be noted that the Follow-up Meeting's Opinion (*1) pointed out that “we are encountering cases wherecompanies proactively explain the reason why they do not comply with a certain principle and that these kinds of
explanatory efforts are preferable to superficial compliance" (*2).

(*1) "Follow-up Meeting on the Stewardship Code and Corporate Governance Code" Opinion (1)(https://www.fsa.go.jp/en/refer/councils/follow-up/statements.pdf)(*2) Naturally, when explaining the "reasons for not implementing", companies should devise ways to fully gain the understanding ofshareholders and other stakeholders regarding their own responses to the principle of not implementing, and it would be contrary
to the purpose of "Comply or Explain" to limit oneself to superficial explanations using "template" expressions ("The Preamble ofthe “Japan’s Corporate Governance Code [Final Proposal]”).



We hope that this report will be useful for listed companies and other interested parties to get an overview of the statusof listed companies' efforts on corporate governance.

© 2022 Tokyo Stock Exchange, Inc.

1

AgendaI.

Target of Analysis

II. Status of Response to Newly Established and Revised Principles
i. Board Independence
ii. Promoting Diversity
iii. Sustainability and ESG
iv. Other Items
III. Reference Materials© 2022 Tokyo Stock Exchange, Inc.

2

I . Target of Analysis© 2019 Tokyo Stock Exchange, Inc.

I. Target of Analysis
 This report is based on the “comply or explain” disclosure in Governance Reports
submitted by companies listed on the 1st section, 2nd sections and JASDAQ
Standard (3,311 companies) of the TSE, by December 31, 2021.
* The contents of the principles for Prime Market listed companies are not taken into account in thecompilation of this report, as they will be applied from the Governance Report to be submitted after the first
AGM held after April 1, 2022.
[Status of disclosure on status of response to the code by market segment] *The red box indicates the target of this report.

Market segment

Number of disclosing
companies
December
2021[Ref.] August2020

1st Section

2,182

2,172

2nd Section

472

480

JASDAQ Standard *

657

662

Mothers

421

326

JASDAQ Growth

37

37

3,769

3,677

Total

Scope of Comply or Explain*

All 83 principles- General Principles: 5 principles- Principles: 31 principles- Supplementary Principles: 47 principles

General Principles: 5 principles* JASDAQ Standard companies traditionally applied to only General Principles. Since all JASDAQ Standard listed companies havechosen the Standard Market as the new market segment from April 2022, all have submitted Governance Reports that addresses
all 83 principles of the Code by the end of December 2021.
© 2022 Tokyo Stock Exchange, Inc.

4

[Reference] Summary of newly established and revised principles (1)i. Ensuring Board Independence
Revised

4.8

Companies listed on the Prime Market should therefore appoint at least one-third of their directors (the majority of
directors if deemed necessary) as independent directors that sufficiently have such qualities. ★

Revised4.10.1Companies listed on the Prime Market should basically have the majority of the members of an independent
nomination committee and remuneration committee under the board be independent directors, and should disclosethe mandates and roles of the committees, as well as the policy regarding the independence of the composition.★

Revised

4.11

The board should be well balanced in knowledge, experience and skills in order to fulfill its roles and responsibilities,
and it should be constituted in a manner to achieve both diversity, including gender, international experience, work
experience and age, and appropriate size.

Revised4.11.1The board should identify the skills, etc. that it should have in light of its managing strategies, and disclose the
combination of skills, etc. that each director possesses. When doing so, independent director(s) with management
experience in other companies should be included.

ii. Promoting Diversity in Core Human Resources
New

2.4.1

Companies should present their policies and voluntary and measurable goals for ensuring diversity in the promotion
to core human resources, such as the promotion of women, foreign nationals and midcareer hires to middle
managerial positions, as well as disclosing their status.

iii. Attention to Sustainability and ESG
Revised

2.3.1

New

3.1.3

New

4.2.2

The board should recognize that dealing with sustainability issues are important management issues that can leadto earning opportunities as well as risk mitigation, and should further consider addressing these matters positively
and proactively in terms of increasing corporate value over the mid-to long-term.
Companies should appropriately disclose their initiatives on sustainability when disclosing their management
strategies.
Companies listed on the Prime Market should enhance the quality and quantity of disclosure based on the TCFD
recommendations or an equivalent framework. ★
The board should develop a basic policy for the company's sustainability initiatives.
* ★ For Prime Market listed companies only (to be applied from Governance Reportsubmitted after the first AGM held after April 4, 2022)© 2022 Tokyo Stock Exchange, Inc.

5

[Reference] Summary of newly established and revised principles (2)iv. Other Individual Items
Revised

1.2.4

Companies listed on the Prime Market should make the Electronic Voting Platform available, at least to institutional
investors. ★

Revised

3.1.2

Companies listed on the Prime Market should disclose and provide necessary information in their disclosure
documents in English.★

Revised

4.3.4

The board should appropriately establish effective internal control and proactive enterprise risk management
systems on an enterprise basis and oversee the operational status.

Revised4.4

Kansayaku and the kansayaku board should make decisions from an independent and objective standpoint when
executing their roles and responsibilities including appointment and dismissal of kansayaku and external auditors,
etc.

New

4.8.3

Companies that have a controlling shareholder should either appoint at least one-third of their directors (themajority of directors if listed on the Prime Market★) as independent directors or establish a special committee todeliberate and review material transactions or actions that conflict with the interests of the controlling shareholder
and minority shareholders.

Revised4.13.3Companies should ensure coordination between the internal audit department, directors and kansayaku by
establishing a system in which the internal audit department appropriately reports directly to the board and thekansayaku board in order for them to fulfill their functions.

Revised5.1.1

Taking the requests and interests of shareholders into consideration, to the extent reasonable, the senior
management, directors, including outside directors, and kansayaku, should have a basic position to engage indialogue (management meetings) with shareholders.

New

5.2.1

In formulating and announcing business strategies, etc., companies should clearly present the basic policy
regarding the business portfolio decided by the board and the status of the review of such portfolio.
* ★ For Prime Market listed companies only (to be applied from Governance
Report submitted after the first AGM held after April 4, 2022)© 2022 Tokyo Stock Exchange, Inc.

6

II. Status of Response to Newly Established and Revised Principles© 2019 Tokyo Stock Exchange, Inc.

II.（i） Board Independence
Compliance rate(compared to Aug, 2020)
1st
2nd
JASDAQ
Section Section Standard

Revisedprinciples

Content

4.11

The board should be well balanced in knowledge, experience and skills in order to fulfill its
roles and responsibilities, and it should be constituted in a manner to achieve both diversity,
including gender, international experience, work experience and age, and appropriate size.

64.2%(-2.7pt)

49.8%

4.11.1The board should identify the skills, etc. that it should have in light of its managing strategies,
71.1%
57.8%
and disclose the combination of skills, etc. that each director possesses. When doing so,(-25.8pt) (-38.6pt)
independent director(s) with management experience in other companies should be included.

43.8%

79.2%
(+3.0pt)【Status of response to Supplementary Principle 4.11.１（TOPIX100）】
Status of compliance
Explain

How to disclose
combination of skills, etc.

40

33

Others6 companies

Where to refer tocombinations of skills, etc.

26

13

25

20

Comply94 companies

12
Skills Matrix
81




*

1

0
Governance

Convening

reportnoticeWebsiteAnnual report

Yuho *For supplementary principle 4.11.1, the compliance rate decreased after the revision: In terms of the content of explain, there are many examples ofconsidering the disclosure of a combination of skills, etc. in the future.
Many companies prepare and disclose a skills matrix regarding the combination of skills of directors, but there are also cases where the combination of skills is
written.
In addition to being included in governance report, there are some cases of using the convening notice and website as reference.
Yuho is a statutory annual securities report in Japan.

© 2022 Tokyo Stock Exchange, Inc.

8

II.（ii） Promoting Diversity
Newly
establishedprinciples
2.4.1

Compliance rate

Content
Companies should present their policies and voluntary andmeasurable goals for ensuring diversity in the promotion tocore human resources, such as the promotion of women,
foreign nationals and midcareer hires to middle managerial
positions, as well as disclosing their status.

1st Section

2nd Section

JASDAQ
Standard

66.8%

46.2%

37.9%

【Status of response to Supplementary Principle2.4.1（TOPIX100）】
Status ofcompliance

Explain

Status of disclosure of policies, current status, and setting of
measurable goals in core human resources

86

11 Companies

Comply89 Companies
FemaleMeasurable goals

22

21

Foreigner

Midcareer

About 70% of the companies listed on the first section of the market comply with 2.4.1, but these disclosures seem to be wide, withsome companies describing their approach, measurable goals, and status in terms of promoting women, non-Japanese, and mid-career hires
to core positions, while others do not describe certain attributes.
(*) If there are any items that do not provide "voluntary and measurable goals" for the promotion to core human resources such as thepromotion of women, foreign nationals and midcareer hires to middle managerial positions they are required to indicate this fact and thereasons for it in the corporate governance report.
Looking at the disclosure details of companies complying with the principle by TOPIX 100, almost all companies set measurable goals of
female to core positions. On the other hand, only about 20 companies set measurable goals for the promotion of foreigner (nonJapanese) and mid-career hires to core positions, which is relatively low compared to women.
(*) Other attributes included those related to age (promotion of young managers).

© 2022 Tokyo Stock Exchange, Inc.

9

II.（iii）a Sustainability and ESG
Newlyestablished andrevisedprinciples

Content

Compliance rate(compared to Aug, 2020)
1st
2nd
JASDAQ
Standard
SectionSection

2.3.1

The board should recognize that dealing with sustainability issues
are important management issues that can lead to earning
opportunities as well as risk mitigation, and should further
consider addressing these matters positively and proactively interms of increasing corporate value over the mid-to long-term.

93.9%(-6.0pt)

94.3%(-5.7pt)

92.4%

3.1.3
[New]

Companies should appropriately disclose their initiatives onsustainability when disclosing their management strategies. They
should also provide information on investments in human capitaland intellectual properties in an understandable and specificmanner, while being conscious of the consistency with their own
management strategies and issues.

66.2%

58.3%

56.2%

4.2.2
[New]

The board should develop a basic policy for the company's
sustainability initiatives from the perspective of increasing
corporate value over the mid- to long- term. In addition, in light of
the importance of investments in human capital and intellectual
properties, the board should effectively supervise the allocation ofmanagement resources and the implementation of businessportfolio strategies to ensure that they contribute to thesustainable growth of the company.

78.8%

64.8%

58.9%

More than 90% of companies comply with 2.3.1, and the majority of companies recognize
sustainability as important management issues and further consider addressing these matters.

（※）Many of the companies that have explained to 2.3.1 also indicate that they will be making further efforts to address
sustainability issues in the future, taking sustainability issues seriously.

On the other hand, only around 60-80% of companies formulate a basic sustainability policy(Supplemental Principle 4.2.2) and disclose their initiatives (Supplemental Principle 3.1.3).

© 2022 Tokyo Stock Exchange, Inc.

10II.（iii）ｂ Sustainability and ESG【Status of response to Supplementary Principle3.1.3（TOPIX100）】

Status ofcompliance

Explain

References for sustainability initiatives, human capital, andintellectual property investment
75

6 companies（*）Sustainability Report, CSR Report, Other Reports

48

38

Comply94 companies

23
8
Website[Reference]TCFD Disclosure
No mention
In the process

9

9

Done
76





Annual report

Others (*)

Business planYuho

2
No mention

Mentions for human capital and intellectual property
investment

Category

No. ofCompanies

Comply with Supplementary Principle3.1.3

94

Ratio

- Investment to Human Capital

71

75.5%

- Investment to Intellectual Property

67

71.3%

In many cases, when disclosing the supplementary principle 3.1.3, reference is made to other statutory or
voluntary disclosure.

（**）In some cases, governance reports do not mention investments in human capital and intellectual property, which are required
to be disclosed.

Disclosure based on TCFD or equivalent framework to be applied to companies listed on the prime market after
the transition to the new market segmentation in April 2022: 76 of TOPIX 100 companies have alreadyresponded to this, and 9 are considering it.

© 2022 Tokyo Stock Exchange, Inc.

11II.（iv）a Other Items (Companies with Controlling Shareholders)Compliance rate *Newlyestablishedprinciples

Content

4.8.3

Companies that have a controlling shareholder should either appoint at least one-third of theirdirectors (the majority of directors if listed on the Prime Market★) as independent directors or
establish a special committee to deliberate and review material transactions or actions thatconflict with the interests of the controlling shareholder and minority shareholders.
1st Section

No. ofCompanies

Ratio

More than 1/2

15More than 1/3 or more – 1/2Less than 1/3
Total

2nd Section（N＝96）

JASDAQ
Standard（N＝141）

71.9%

62.5%

62.4%

* The compliance rate in Supplementary Principle 4.8.3 is calculated using listed companies with controlling shareholders as the denominator.

【Principle4.8.3 - Comply】
Ratio of Independent
Directors

1st Section（N＝231）

2nd Section

No. ofcompanies

Ratio

9.0%

With Special
Committee
0

2

123

74.1%

33

28

16.9%

166

ー

No. ofcompanies

Ratio

3.3%

With Special
Committee
0

4

4.5%

With Special
Committee
1

45

75.0%

4

53

60.2%

3

7

13

21.7%

3

31

35.3%

5

40

60

ー

7

88

ー

9

【Principle4.8.3 - Explain】

1st Section
No. ofcompanies

Category
Total

JASDAQ Standard

2nd Section
Ratio

65

No. ofcompanies

Ratio

36

JASDAQ Standard
No. ofcompanies

Ratio

53

- Increase independent directors (planning to )

32

49.2%

24

66.7%

20

37.7%

- Establish Special Committee

22

33.8%

13

36.1%

16

30.2%

(planning to )More than 80% of the companies listed on the First Section of the Tokyo Stock Exchange that comply with the supplementary
principle 4.8.3 appoint at least one-third independent directors.



There are a certain number of companies that state the fact that they have a special committee, and there are also companies
that implement this together with the appointment of at least one-third of independent directors.
(*) If a company establishes a special committee in accordance with this principle, it is desirable to include a statement to that effect ingovernance report, but there have been cases of companies with less than one-third of independent outside directors complying withthis principle and not stating that they establish a special committee.

Even if a company has explained, there is a certain percentage of companies that plan to increase the ratio of independent outside
directors or establish a special committee.

© 2022 Tokyo Stock Exchange, Inc.

12

II.（iv）b Other Individual Items
Compliance rate(compared to Aug, 2020)

Newly
establishedand revised
principles

Content

4.3.4

The board should appropriately establish effective internal
control and proactive enterprise risk management systems onan enterprise basis and oversee the operational status,
besides utilizing the internal audit department.

99.5%(-0.5pt)

99.6%(-0.4pt)

99.7%

4.4

Kansayaku and the kansayaku board should make decisions
from an independent and objective standpoint when
executing their roles and responsibilities including
appointment and dismissal of kansayaku and external
auditors, etc.

100.0%(+0.0pt)

100.0%(+0.0pt)

100.0%

4.13.3Companies should ensure coordination between the internal
audit department, directors and kansayaku by establishing asystem in which the internal audit department appropriately
reports directly to the board and the kansayaku board inorder for them to fulfill their functions.

99.1%(-0.9pt)

98.1%(-1.7pt)

99.5%

5.1.1

Taking the requests and interests of shareholders into
consideration, to the extent reasonable, the senior
management, directors, including outside directors, andkansayaku, should have a basic position to engage indialogue (management meetings) with shareholders.

99.2%(-0.7pt)

98.9%(-0.9pt)

98.9%

5.2.1
[New]

In formulating and announcing business strategies, etc.,
companies should clearly present the basic policy regarding
the business portfolio decided by the board and the status of
the review of such portfolio.

81.6%

66.7%

56.2%

© 2022 Tokyo Stock Exchange, Inc.

1st Section 2nd Section

JASDAQ
Standard13

Ⅲ. Reference Materials© 2019 Tokyo Stock Exchange, Inc.

Ⅲ.（i） Status of compliance with all principles (As of December 31, 2021)
Compliance rate
Principle

1stSection[Reference]compared toAug, 2020

2nd
Section

1
1.1
1.1.1
1.1.2
1.1.3
1.2
1.2.1
1.2.2
1.2.3
1.2.4 [Revised]
1.2.5
1.3
1.4
1.4.1
1.4.2
1.5
1.5.1
1.6
1.7
2
2.1
2.2
2.2.1
2.3
2.3.1 [Revised]
2.4
2.4.1 [New]
2.5
2.5.1
2.6
3
3.1
3.1.1
3.1.2 [Revised]
3.1.3 [New]
3.2
3.2.1
3.2.2

99.95%
100.00%99.82%
99.95%
99.95%
99.86%
99.91%
98.81%
99.63%
63.47%
97.02%
98.76%
93.72%
99.68%
99.91%
100.00%100.00%100.00%100.00%99.86%
100.00%100.00%99.40%
98.95%
93.86%
99.77%
66.82%
99.91%
98.95%
97.48%
99.86%
96.20%
99.63%
80.11%
66.18%
100.00%99.13%
99.77%+0.00pt±0.00pt+0.19pt+0.05pt-0.05pt+0.14pt-0.05pt+0.88pt+0.23pt+7.17pt+0.89pt+0.42pt+2.79pt+0.19pt+0.14pt±0.00pt±0.00pt±0.00pt+0.05pt-0.09pt+0.09pt+0.14pt+0.00pt-0.82pt-5.96pt+0.09ptー+0.00pt+0.74pt+1.21pt-0.05pt+1.44pt+0.09pt+0.41ptー±0.00pt+0.42pt+0.05pt

100.00%100.00%99.36%
100.00%100.00%99.79%
99.79%
93.43%
97.25%
12.92%
87.50%
96.40%
87.08%
100.00%100.00%100.00%100.00%100.00%99.79%
100.00%100.00%100.00%99.15%
99.15%
94.28%
99.58%
46.19%
99.15%
95.34%
95.13%
100.00%90.68%
99.58%
30.72%
58.26%
100.00%95.97%
100.00%Compliance rate

[Reference]
JASDAQ [Reference] [Reference]compared toPrimeStandard
Standard
Aug, 2020
Market*Market*+0.21pt±0.00pt-0.01pt±0.00pt±0.00pt-0.00pt-0.21pt+1.97pt+0.58pt-2.28pt+1.04pt+0.56pt+1.45pt+0.21pt+0.21pt±0.00pt±0.00pt±0.00pt+0.20pt±0.00pt±0.00pt±0.00pt+0.19pt-0.85pt-5.72pt+0.20pt
ー-0.85pt+0.13pt+0.75pt±0.00pt+1.09pt-0.22pt-2.82ptー±0.00pt+1.60pt±0.00pt

100.00%100.00%99.09%
99.54%
100.00%98.93%
99.54%
83.71%
96.35%
10.50%
89.35%
91.93%
90.56%
100.00%100.00%99.85%
100.00%99.85%
99.54%
100.00%99.70%
98.78%
93.15%
96.50%
92.39%
98.48%
37.90%
99.24%
90.26%
98.02%
100.00%83.11%
99.85%
29.53%
56.16%
100.00%96.50%
99.85%

100.00%100.00%99.84%
99.95%
99.95%
99.89%
99.89%
98.97%
99.56%
69.97%
97.33%
99.18%
94.12%
99.67%
100.00%100.00%100.00%100.00%100.00%99.84%
100.00%100.00%99.51%
99.13%
93.85%
99.84%
70.02%
99.95%
99.02%
97.93%
99.89%
96.95%
99.73%
85.36%
66.70%
100.00%99.35%
99.78%

99.93%
100.00%99.32%
99.80%
100.00%99.39%
99.73%
90.17%
97.49%
15.66%
90.17%
94.44%
89.69%
99.93%
99.86%
99.93%
100.00%99.93%
99.73%
100.00%99.86%
99.46%
96.41%
97.69%
93.36%
99.05%
43.39%
99.32%
93.83%
96.41%
99.93%
87.66%
99.59%
35.25%
58.58%
100.00%96.68%
99.86%* Classification according to the choice of TSE new market segments after April 2022.
** The compliance rate in Supplementary Principle 4.8.3 is calculated using listed companies
with controlling shareholders as the denominator.

© 2022 Tokyo Stock Exchange, Inc.

Principle

1stSection[Reference]compared toAug, 2020

2nd
Section

4
4.1
4.1.1
4.1.2
4.1.3
4.2
4.2.1
4.2.2 [New]
4.3
4.3.1
4.3.2
4.3.3
4.3.4 [Revised]
4.4[Revised]
4.4.1
4.5
4.6
4.7
4.8
[Revised]
4.8.1
4.8.2
4.8.3 ** [New]
4.9
4.10
4.10.1 [Revised]
4.11 [Revised]
4.11.1 [Revised]
4.11.24.11.34.12
4.12.1
4.13
4.13.14.13.24.13.3 [Revised]
4.14
4.14.14.14.2
55.1
5.1.1 [Revised]
5.1.2
5.1.3
5.2
5.2.1 [New]100.00%99.95%
99.68%
89.00%
76.58%
95.42%
83.36%
78.83%
99.77%
98.81%
91.80%
89.78%
99.45%
99.95%
99.77%
100.00%99.91%
99.91%
92.03%
95.46%
93.31%
71.86%
98.40%
96.93%
74.15%
79.24%
71.13%
99.91%
87.99%
100.00%99.77%
99.91%
100.00%100.00%99.08%
99.54%
99.77%
98.85%
100.00%99.45%
99.22%
99.45%
99.95%
85.24%
81.62%+0.05pt-0.05pt-0.04pt+0.74pt+3.61pt+1.49pt+5.83ptー+0.05pt+0.24pt+3.95pt+3.04pt-0.50pt+0.05pt+0.05pt+0.05pt+0.18pt+0.23pt-3.05pt+1.54pt+0.95ptー+0.47pt+2.73pt+10.85pt+3.04pt-25.79pt+0.00pt+3.32pt+0.32pt+0.42pt+0.37pt±0.00pt±0.00pt-0.92pt+0.00pt+0.14pt+0.19pt+0.09pt+0.00pt-0.69pt+0.05pt+0.18pt+0.85ptー100.00%100.00%99.36%
76.91%
58.69%
87.71%
55.72%
64.83%
99.36%
97.03%
82.63%
80.30%
99.58%
100.00%99.79%
100.00%99.15%
98.73%
77.97%
83.69%
78.81%
62.50%
93.86%
91.31%
40.68%
64.19%
57.84%
100.00%68.01%
100.00%98.94%
99.79%
100.00%100.00%98.09%
98.94%
98.94%
95.34%
99.79%
97.67%
98.94%
96.82%
99.15%
67.16%
66.74%[Reference]
JASDAQ [Reference] [Reference]compared toPrimeStandard
Standard
Aug, 2020
Market*Market*±0.00pt±0.00pt-0.01pt+0.45pt-0.06pt+3.34pt+4.05ptー+0.20pt+0.16pt+2.42pt+1.55pt-0.42pt±0.00pt+0.20pt±0.00pt+0.40pt+0.19pt+2.34pt+2.23pt+0.90ptー+0.11pt+1.73pt+3.80pt-2.68pt-38.62pt+0.21pt+0.93pt±0.00pt+0.61pt+0.41pt±0.00pt±0.00pt-1.70pt+0.19pt-0.23pt-0.91pt-0.00pt-0.25pt-0.85pt-0.05pt-0.22pt-1.59ptー100.00%99.54%
99.39%
55.71%
36.07%
76.41%
51.90%
58.90%
98.33%
90.87%
74.28%
66.21%
99.70%
100.00%99.39%
100.00%98.78%
95.59%
62.25%
78.84%
75.19%
62.41%
92.09%
86.15%
28.92%
49.77%
43.84%
99.70%
36.23%
99.85%
98.48%
99.70%
99.85%
100.00%99.54%
94.52%
95.89%
87.37%
99.85%
97.11%
98.93%
96.65%
99.54%
48.25%
56.16%

100.00%99.95%
99.73%
91.02%
78.40%
96.46%
86.56%
80.25%
99.73%
98.97%
92.66%
90.97%
99.40%
100.00%99.78%
100.00%99.95%
99.89%
92.33%
96.30%
94.83%
73.37%
98.53%
97.39%
77.75%
81.39%
73.07%
99.89%
89.93%
100.00%99.84%
99.89%
100.00%100.00%99.29%
99.51%
99.84%
99.08%
100.00%99.62%
99.18%
99.67%
99.95%
87.70%
83.79%

100.00%99.80%
99.39%
67.73%
50.58%
83.19%
56.54%
63.73%
99.05%
94.51%
80.00%
74.78%
99.66%
99.93%
99.59%
100.00%99.12%
97.63%
73.90%
83.25%
78.71%
63.79%
93.97%
89.76%
38.85%
58.58%
52.34%
99.86%
56.07%
99.93%
98.85%
99.80%
99.93%
100.00%98.71%
97.15%
97.69%
92.34%
99.86%
97.63%
99.05%
97.08%
99.53%
59.93%
62.85%

15

[Attention] Governance Report under New Market Structure Under the new market structure, domestic companies are required to submit the CG Report disclosing theirapproach to each of the principles in the Corporate Governance Code, on a comply or explain basis.
 The extent of disclosure required of each company is based on the new market segment company has
chosen.
・Prime Market: General Principle・Principle・Supplementary Principle
・Standard Market: General Principle・Principle・Supplementary Principle (excluding Principles
for Prime listed companies)

・Growth Marke: General Principle
 For Prime listed companies, the CG Report to be submitted immdiately after the Annual General Meetingthat they will be holding after April 4th, 2022, should include 1 and 2 listed below. (Some companies havealready included them in the CG Report submitted by the end of 2021, however, ALL Prime listed companies
should include the two items, starting from April 4th, 2022)
1. Comply or Explain of Principles applied only to Prime listed companies(*1)
2. Disclosures of the Principles applied only to Prime listed companies(*2)*1: Supplementary Principle1.2.4 (latter part), Supplementary Principle3.1.2(latter part),
Supplementary Principle3.1.3(latter part), Principle4.8, Supplementary Principle4.8.3,
Supplementary Principle4.10.1(latter part)*2: Supplementary Principle3.1.3 (latter part), Supplementary Principle4.10.1 (latter part) For Standard and Growth listed companies, there is no change in the content of principles to be "comply or
explain". Please update the Governance Report and submit it immediately after the AGM.
© 2022 Tokyo Stock Exchange, Inc.

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