PRESS RELEASE
July 4, 2024
To AllName of Company: Hokuetsu Corporation
Name of Representative: Sekio Kishimoto, President and CEO(Securities Code: 3865 (Prime Market, Tokyo Stock Exchange))
Inquiries: Yoshiharu Togawa, General Manager, Public Relations OfficeTel: +81 3-3245-4500
Notice of Letter to Oasis
Hokuetsu Corporation (“Company”) held its 186th Annual General Meeting ofShareholders (the “Annual General Meeting of Shareholders”) on June 27, 2024 andacknowledged that, at the Annual General Meeting of Shareholders, the number ofvoting rights in favor of Proposals 5 to 9, from Oasis Japan Strategic Fund Ltd. andOasis Investments II Master Fund Ltd. (“Oasis et al.”), was less than the total
number of voting rights (687,538) held by Oasis et al. and Daio Kaiun et al., as statedin the most recent statement of changes submitted by each company regarding theCompany’s shares (excluding the proposal to appoint Ms. Wendy Shiba).
Given that Daio Kaiun had announced its approval of Oasis’s shareholder proposal prior
to this Annual General Meeting of Shareholders, Oasis et al. and Daio Kaiun et al. should have atleast agreed to the proposal from Oasis. This situation is extremely unreasonable, andit is strongly suspected that Oasis et al. neglected to submit a statement of changes.
Therefore, the Company has sent a letter (Attachment 1) to ask Oasis Management Company
Limited (“Oasis”) whether or not all the statements in the most recently submitted statement ofchanges (7) dated March 9, 2023 (the “Latest Oasis Statement of Changes”) are accurate, and if
so, why the discrepancy described above has arisen.
During preparation for this Annual General Meeting of Shareholders, while investigating
the beneficial shareholders, the Company discovered that the number of share certificates, etc.
for the Company held by Oasis et al. deviated significantly from the number of share certificates,etc. stated in the Latest Oasis Statement of Changes. This discrepancy is suspected to be a resultof the following: (i) Oasis et al. disposed of 8,345,000 of the Company’s shares but neglected tosubmit a statement of changes to that effect, or (ii) despite Oasis et al. lending 8,345,000 of theCompany’s shares to a third party, they neglected to submit a statement of changes to change theentry in the “Significant contracts related to said stocks, etc. such as collateral agreements”
column in the statement of large-volume holdings. Therefore, the Company sent a letter to Oasis
on April 23, 2024 (Attachment 2, “April 23 Letter”) requesting an explanation regarding the same
topic, which is attached for your reference. However, regrettably, the Company has not received
a response to the April 23 Letter from Oasis to date.
Oasis has stated that it accepts the Japan’s Stewardship Code, but unlike many
institutional investors who accept the Code, it does not follow the requirement that “whenthey have a practice of lending stocks across the determination date of the votingright, their voting policy should include a policy on lending stocks” (the policy
statement for stock lending transactions) in Guidance 5-2, and the disclosure of
voting results in Guidance 5-3 under Principle 5.

Particularly for the former

requirement, Oasis does not explain why Oasis does not describe its policy.

TheCompany is concerned that the discrepancy between the number of voting rights stated in theLatest Oasis Statement of Changes Report and the actual voting results may be due in part toOasis’ attitude toward the Japan’s Stewardship Code.

The Company requests that Oasis etal. comply with Guidance 5-2 and 5-3 above, at least in relation to the Company, andthat Oasis disclose its shareholding status and exercise its voting rights in atransparent manner as a major shareholder with more than 10% of the Company’sshares.
For your information, the Company states in its press release, “Notice Concerning
Results of Resolutions of the 186th Annual General Meeting of Shareholders” dated June 27, 2024,“Dismissal of One (1) Representative Director and Dismissal of Four (4) Outside Directors
proposed from Oasis Group were rejected by more than 99% of the shareholders except Oasis
Group and . . . Daio Kaiun Group.” With regard to the “99%,” if the number of voting
rights held by the Oasis Group is calculated as 338,423, as stated in the Latest Oasis
Statement of Changes, the total number of voting rights held by Oasis et al. and Daio
Kaiun et al. exceeds the number of voting rights in favor of the proposals made byOasis, which is an illogical result.

Therefore, the Company has conservatively calculated

the number of voting rights held by the Oasis Group as 255,000, by deducting thenumber of shares the Company suspects that Oasis may have disposed of or lent toa third party.
EndAttachment 1
July 4, 2024
Oasis Management Company Limited
Chief Investment Officer Mr. Seth H. Fisher
Hokuetsu Corporation
Sekio Kishimoto, President and CEO
Notice Concerning the Filing of a Statement of Changes Concerning the Company'sShares
Hokuetsu Corporation (“Company”) held its 186th Annual General Meeting ofShareholders (the “Annual General Meeting of Shareholders”) on June 27, 2024, where thenumber of voting rights exercised in favor of Proposals 5 to 9 (“Oasis Proposals”), from Oasis
Japan Strategic Fund Ltd. and Oasis Investments II Master Fund Ltd. (“Oasis et al.”) was asfollows.
Proposal 5621,681

Proposal 6

Dismissal of Messrs. Mitsuyasu Iwata (621,225), Kazuo Nakase(621,225), Hiromitsu Kuramoto (619,485) and Ms. Hiroko Nihei(619,248)

Proposal 7

Appointment of Ms. Wendy Shiba (695,241) and Messrs. Kenneth
Nysten (683,677), Yuuichiro Nakajima (683,370), Michael Baisley(681,870) and Osamu Watanabe (619,332)

Proposal 8637,712

Proposal 9636,065

Based on the announcement by DAIO KAIUN CO., LTD. on June 10, 2024, titled“Exercise of Voting Rights at the Ordinary General Meeting of Shareholders of Hokuetsu
Corporation [Company note: translated into English by the Company],” in which Daio Kaiun
expressed support for the Oasis’s shareholder proposal, it is presumed, at least, that Oasis et al.
and Daio Kaiun and its joint holders (“Daio Kaiun et al.”) would have voted in favor of the Oasis
Proposals.

However, given the number of shares recorded in the most recently submitted

statement of changes (7) dated March 9, 2023 by Oasis et al. (the “Latest Oasis Statement ofChanges”), which indicates a holding of 33,842,300 share certificates, etc. (equivalent to338,423 voting rights), and the number of shares recorded in the most recently submitted
Statement of Changes No. 13 by Daio Kaiun et al. on December 25, 2023, which indicates aholding of 34,911,500 share certificates, etc. (equivalent to 349,115 voting rights), it seems highly
unreasonable that the number of voting rights exercised in favor of the Oasis Proposals,

excluding the proposal for the appointment of Ms. Wendy Shiba under Proposal 7, would fall
below the total number of voting rights held by Oasis et al. and Daio Kaiun et al., as disclosed intheir respective statement of changes (687,538 voting rights). Consequently, there is a strong
suspicion that the actual number of the Company’s shares held by Oasis et al. or Daio Kaiun etal. may differ from the numbers stated in the statement of changes.
In this regard, as per the inquiry in our letter dated April 23, 2024, “Notice Concerning
the Filing of a Statement of Changes Concerning the Company’s Shares,” (“the April 23 Letter”),
during the Company’s investigation into the beneficial shareholders, suspicions were raised
regarding the fact that the number of share certificates, etc. for the Company’s shares held byOasis et al. deviated significantly from the number of share certificates, etc. for the Company’sshares as stated in the Latest Oasis Statement of Changes.

This discrepancy is suspected to bea result of the following: (i) Oasis et al. disposed of 8,345,000 of the Company’s shares but
neglected to submit a statement of changes to that effect, or (ii) despite Oasis et al. lending
8,345,000 of the Company’s shares to a third party, they neglected to submit a statement ofchanges to change the entry in the “Significant contracts related to said stocks, etc. such as
collateral agreements” column in the statement of large-volume holdings.

This is further

substantiated by the unusual outcome regarding the voting results on the Oasis Proposals
mentioned above. Additionally, if the number of voting rights (349,115) stated in Daio Kaiunet al.’s statement of changes above is subtracted from the number of votes in favor of theProposal to dismiss director Ms. Hiroko Nihei (619,248), who has the smallest number of votes
cast in favor of the proposal for her dismissal, the remaining number is 270,133.

Whensubtracting this (270,133) from the number of voting rights (338,423) stated in Oasis et al.’s
statement of changes, 68,290 voting rights remain (equivalent to 6,829,000 shares), whichaligns with the Company’s suspicion regarding the negligence to submit a statement of changes
for the 8,345,000 shares as stated in points (i) and (ii) above. This may be explained if, inaddition to those of Oasis et al. and Daio Kaiun et al., there were approximately 1.5 million shares’
worth of third-party votes in favor of the proposal to dismiss Ms. Hiroko Nihei.
Given the recent increase in attention to compliance with statement of large-volume
holdings regulations, as evidenced by the unprecedented public announcement of a enforcementof sanction only for violation of the statement of large-volume holdings regulations by theSecurities and Exchange Surveillance Commission on June 28, 2024, the Company requests
prompt and reasonable verification of whether all the information in the Latest Oasis Statementof Changes is accurate, and if so, an explanation of the unusual outcome regarding the voting
results on the Oasis Proposals as mentioned above to the general shareholders of the Company.
Although the Company requested an explanation in the April 23 Letter as well,unfortunately, the Company has not received a response.

In light of the increasing need tostrengthen the effectiveness of the statement of large-volume holdings system, the Company
asks for your sincere and earnest response to its request, given that information regarding theCompany’s shareholding by Oasis et al. is ever more important for the Company’s generalshareholders in making their investment decisions.
EndAttachment 2April 23, 2024
Oasis Management Company Limited
Chief Investment Officer Mr. Seth H. Fisher
Hokuetsu Corporation
Sekio Kishimoto, President and CEO
Notice Concerning the Filing of a Statement of Changes Concerning the Company'sShares
On April 22 of this year, Hokuetsu Corporation (the “Company”) received a shareholder
proposal dated April 19 (the “Shareholder Proposal”) from Oasis Japan Strategic Fund Ltd. andOasis Investments II Master Fund Ltd., which are understood to be affiliates of your company.
The Company is in the process of reviewing its formal requirements, among other matters. Inconnection with this, when the Company examined the Company’s shareholder registers as of therecord date of March 31, 2024, it found that the number of shares effectively held by yourcompany (hereinafter referred to as the “Actual Number of Shares Held”) decreased by 8,345,000,
and approximately 4.44% in terms of the holding ratio of share certificates, etc., compared to theActual Number of Shares Held as of March 31, 2023.
However, the latest statement of changes (the “Statement of Changes”) submitted byyour company concerning the Company’s shares was the statement of changes No. 7, dated March9, 2023, which indicated an increase of 1% or more in the holding ratio of share certificates, etc.
as of March 2, 2023, and no additional statements of changes have been submitted regarding theCompany’s shares to date.
As you may be aware, under the Financial Instruments and Exchange Act, a statementof changes must be submitted within five (5) business days from the date of occurrence of theevent that triggers the submission (Article 27-25, Paragraph 1, the Financial Instruments andExchange Act). However, your company has not submitted a statement of changes indicating adecrease of 1% or more in the holding ratio of share certificates, etc. for more than three weeks
since March 31, 2024, which is the latest possible date of occurrence of the event.

This may be

the result of (i) neglecting to submit the required statement of changes, or (ii) your company
merely lending out the 8,345,000 shares, meaning that the holding ratio of share certificates, etc.
in the Company’s shares has not decreased.

However, as you may be aware, if the above-

mentioned lending of shares has taken place, a statement of changes indicating that the shareswere lent out, along with the name of the counterparty and the quantity in the “Significant
contracts related to said stocks, etc. such as collateral agreements” column must be submitted

(Question 9 in the Q&A on Statement of Large-Volume Holdings by the Planning and Market
Bureau of the Financial Services Agency, revised In 2020). Yet, such a statement of changes has
not been submitted to date, more than three (3) weeks after March 31, 2024, which is the latest
possible date of occurrence of the event. Additionally, your company delayed submission of theentry in the “Significant contracts related to said stocks, etc. such as collateral agreements”
column of the statement of large-volume holdings by more than one (1) month in the correction
report submitted on October 26, 2021, and by more than four (4) months in the statement ofchanges No. 4 submitted on August 16, 2022.
In light of the above, regrettably, the Company cannot help but suspect that yourcompany has either disposed of 8,345,000 of the Company’s shares without submitting thenecessary statement of changes or has lent out 8,345,000 of the Company’s shares without
submitting the required statement of changes to change the entry in the “Significant contracts
related to said stocks, etc. such as collateral agreements” column of the statement of large-volume
holdings. As noted above, your Company group has already made its Shareholder Proposal, andthe information regarding the shareholding status of your Company group in the Company’sshares is extremely important for the general shareholders of the Company in making theirinvestment decisions.

Additionally, the “Report of the Working Group on the Tender Offer

System and Statement of Large-Volume Holdings System” published by the Financial System
Council on December 25, 2023, clearly states that “With the revision of the Financial Instruments
and Exchange Act in 2008, the non-submission and false reporting of statements of large-volume
holdings were made subject to the administrative monetary penalty system from the perspectiveof deterring violations of the statement of large-volume holdings system. However, delays insubmitting statements of large-volume holdings and other issues have continued, and it has been
pointed out that the effectiveness of the statement of large-volume holdings system is not being
ensured.

In particular, it has been pointed out that, in recent years, there have been cases where

it is suspected that multiple parties have tacitly coordinated to acquire shares without being
recognized as joint holders due to the difficulty of proving such coordination,” and the necessityof strengthening the statement of large-volume holdings system has been advocated.
Therefore, the Company requests a prompt explanation to the Company and its generalshareholders as to whether its suspicions are justified, or if they are due to somemisunderstanding on the Company’s part.

Moreover, the Company’s stock price, which was

1,320 yen at the closing price on April 19 of this year, surged by 88 yen (6.67%) yesterday (April22), the first business day after April 19, despite no specific Company-related news being
published. It is unclear whether this is related to the Shareholder Proposal, but the Company
wishes to remind your Company group to thoroughly manage information.
End