Disclosure Policy
The Kumagai Gumi Code of Conduct outlines its action principle of disclosing the corporate
information that is necessary for society at large, regardless of whether it is needed byshareholders, customers or the public, in a timely manner with a view toward becoming an open
enterprise. Guided by this principle, the Company will appropriately and impartially disclose
information about its management and business activities and other information to achievesustainable growth and increase corporate value in the medium to long term. The Company iscommitted to engaging in constructive communication with shareholders and other stakeholders.

1. Information disclosure standards
The Company will disclose information in accordance with the Companies Act, the Financial
Instruments and Exchange Act, other laws and regulations and the Rules on Timely Disclosure of
Corporate Information (“Timely Disclosure Rules”) set forth in the Tokyo Stock Exchange’s
Securities Listing Regulations. The Company will actively disclose information it deems helpful tostakeholders even if not required by laws and regulations or the Timely Disclosure Rules.

2. Information disclosure methods
The Company will disclose information according to the methods specified by laws andregulations. Based on the Financial Instruments and Exchange Act, information will be disclosed
through the Financial Services Agency’s Electronic Disclosure System (EDINET), and information
being disclosed based on the Timely Disclosure Rules will be disclosed through the Tokyo Stock
Exchange’s Timely Disclosure Information Transmission System (TDnet). The Company willpromptly post the information disclosed in this way on its website and, as needed, it will makeannouncements to the media. The Company will widely disclose other information using
appropriate methods depending on its content.

3.Prevention of insider trading and fair disclosure of Information
The Company has established the Insider Trading Prevention Internal Regulations to manage
critical information adequately and prevent insider trading, as well as to ensure that information isdisclosed fairly. We will issue notices to employees warning them about insider trading and strive
to increase the Group’s officers and employees' understanding and awareness of the matter.

4. Dialogue with shareholders and investors
The Company will proactively engage in constructive dialogue with shareholders
and investors to increase their understanding of the Group and build trust.
（ 1）

The General Manager of the Administration Division supervises and is responsible forcommunication with shareholders and related measures in connection therewith.

（ 2）

With respect to investor relations(IR) and shareholder relations(SR) including improving
communication with share holders and investors, the Finance Department of theAdministration Division and the Sustainability Promotion Department of the Corporate
Strategy Division in charge of investor relations (IR) compile relevant information about
each division, and work together to promote understanding of the Company.

（ 3）

The Company strives to improve communication with shareholders not only by
individual meetings but also in more effective ways, such as holding financial results
briefings, and business briefings, medium-term management plan briefings, tours ofcompany facilities and construction sites, investor conferences sponsored by the
securities company, and participation in small meetings, among other means.

（4）Comments and requests from shareholders and investors obtained through this
dialogue will be reported to senior executives or the Board of Directors according to theirimportance.

（ 5）

When the above-mentioned communication with shareholders and investors happensand related measures are taken, the Company provides related information to all theshareholders in a fair and equitable manner, in compliance with the internal rules on
preventing insider trading stipulated by the Company.

5. Handling of earning forecasts and other forward-looking statements
Forward-looking statements, such as earnings forecasts and medium-term management plans,
are based on the information that has been obtained as of the time of disclosure and certain
assumptions that are deemed reasonable. Actual performance may vary significantly dependingon various factors.

6. Quiet period
To prevent the leakage of financial information and ensure the fairness of information
disclosure, the Company designates the period from the day after the end of each quarter to theannouncement of its financial results as a quiet period. During the quiet period, the Company
refrains from answering questions or commenting on earnings-related matters. However, thequiet period does not prevent the Company from responding to inquiries or engaging in dialogue
related to information that has already been disclosed and regarding medium- to long-termbusiness strategies, governance, and a wide range of business environments and risks, etc. TheCompany will also disclose information in accordance with laws and regulations and the Timely
Disclosure Rules.

7. Flow for the disclosure of information based on the Timely Disclosure Rules(1) Collection of management-related information
Management Strategy Division Secretariat Department will collect important managementrelated information related to proposals, earnings information or other facts.
(2) Reporting to the information manager
Corporate Strategy Division Secretariat Department will initiate corporate decision-making
procedures as needed and report critical information to the information manager.
(3) Decision to disclose information
The information manager will assess the necessity of disclosing information in compliancewith the Timely Disclosure Rules. If they determine that disclosure is necessary, they will reportto the Board of Directors and direct the department responsible for disclosing information(Corporate Strategy Division Sustainability Promotion Department) to disclose the information.
(4) Information disclosure
The department responsible for disclosing information will disclose information to the Tokyo
Stock Exchange in a timely and appropriate manner. They will also publicize the information tothe media and post it on the Company’s website.

Timely Disclosure System

Submission/
Request for Approval

Board of Directors
President
Determination①

Charge ofInformation

Draft/Report③②
Corporate

Division in③ReportPerson in

Strategy
Division
Secretariat
Department

ReportCharge ofHandling
Information

Corporate④

Strategy
Disclosure

Division

Instruction

Sustainability

Tokyo
Disclosure

Promotion
Department

Date of enactment: March 28, 2024

Stock
Exchange