Translation
Notice: This document is an excerpt translation of the original Japanese document and is only for reference purposes.
In the event of any discrepancy between this translated document and the original Japanese document, the latter shall prevail.
Last Updated: November 11, 2015
Inabata & Co., Ltd.

CORPORATE GOVERNANCE

President: Katsutaro Inabata
Contact: Kenichi Yokota, Director and Managing Executive Officer
Securities Code: 8098
http://www.inabata.co.jp

The corporate governance of Inabata & Co., Ltd. (the “Company”) is described below.
I. Corporate Governance (Basic Views), Capital Structure, Corporate Attributes, and Other Basic
Information
1. Basic Views
The Company’s Mission is to “contribute to the development of society based on the humanitarian spirit of ‘ai (love)’ and ‘kei
(respect).’” This Mission applies to shareholders, business partners, employees and all stakeholders who support our corporate
activities. To execute the mission, the Company maintains an awareness of the importance and necessity of corporate governanceand implements various measures to develop and enhance its system.

[Reasons for Non-compliance with the Principles of the Corporate Governance Code]Update[Principle 3-1. Enhancement of Information Disclosure](v) Although the reasons for each election and appointment of candidates for directors and corporate auditors the Board of Directors
makes based on Principle 3-1 (iv) have not been included in notices of General Meeting of Shareholders, the Company plans toinclude such reasons in notices going forward.
[Principle 4-11. Prerequisite for Securing Viability of the Board of Directors and the Board of Corporate Auditors]
Supplementary Principle 4-11-3
Based on the idea that enhancement of effectiveness of the Board of Directors is important, the Company began performing theirself-evaluation for the first time this year, utilizing an outside consultant. The Company will consider an action plan based on the
results of this evaluation and is also considering disclosure of its overview.
At this point in time, the Company is not implementing the following principles but it is currently constructing an internal system andis aiming for early implementation.
[Principle 1-1] Securing the Rights of Shareholders
Supplementary Principle 1-1-1 (Examination at Board of Directors’ meetingof results of analysis of reasons for votes cast against proposals at a General Meeting of Shareholders)[Principle 1-2] Exercising Rights at General Meetings of Shareholders
Supplementary Principle 1-2-4 (English translations of
notifications of General Meeting of Shareholders)[Principle 2-2] Drafting and Implementation of Code of Conduct
Supplementary Principle 2-2-1 (Report to Board of Directors’
meeting of implementation of Code of Conduct)[Principle 2-3] Sustainability Issues, Including Social and Environmental Matters
Supplementary Principle 2-3-1 (Report to
Board of Directors’ meeting of response to sustainability issues including social and environmental matters)[Principle 4-2] Roles and Responsibilities of the Board of Directors (2)Supplementary Principle 4-2-1 (Examination of
introduction of remuneration system for management that uses the Company’s own stock)[Disclosure Based on the Principles of the Corporate Governance Code]Update[Principle 1-4. Strategically Held Shares]
1. Policy on Strategic Holding of Listed Shares(1) Basic Views
Close business and cooperative relations with various companies are valuable assets to the Company, and the Company believes
the establishment, maintenance and development of these relations improve the Company’s corporate value in the medium and longterm and lead to the benefit of shareholders and investors. Also, as the Company believes the strategic holding of shares of suchcompanies is one effective way to establish, maintain and develop good cooperative relations, the Company owns strategically held
shares.
(2) Decision on Acquisition, Continuous Holding and Disposal of Strategically Held Shares
The Company bases its decision of whether to acquire strategically held shares on whether such holding contributes to theestablishment of cooperative relations, enhances the Company’s corporate value in the medium and long term and leads to thebenefit of shareholders and investors.
More specifically, the Company makes such decisions considering the financial status, liquidity of shares of potential investees,changes in trading volume and income from business with such investees or investee groups as well as outlook thereof in themedium and long term, and economic rationality based on risk and return and other qualitative information in a comprehensive
manner.
After acquiring such shares, the Company reviews the significance of owning strategically held shares annually based on the same
criteria and method as above and explains the rationality of such holding at the Board of Directors’ meetings. The Company disposesof shares the holding of which is not considered significant, while considering timing and the effect on the market and the business.
2. Criteria for Exercise of Voting Rights for Strategically Held Shares
In principle, the Company exercises voting rights for all agendas in order to exercise its rights as a shareholder.
While taking note of the main purpose of strategic holding (maintenance and enhancement of good cooperative relations), theCompany reviews agendas and exercises voting rights based on the judgment criteria of whether sustainable growth of investees andimprovement of corporate value in the medium and long term can be expected.
[Principle 1-7. Related Party Transactions]
The Company shall obtain approval of the Board of Directors in accordance with the Regulations for the Board of Directors when acompetitive transaction of directors or a transaction between the Company and directors is conducted. In addition, the Company
annually reviews whether there is any related party transaction which involves directors or corporate auditors.

1Regarding any transaction with major shareholders, the Company determines a price and other terms and conditions in the same
way as for general transactions after individual negotiation and discloses details of such transactions in securities reports, etc.
[Principle 3-1. Enhancement of Information Disclosure](i) With the Mission of contributing to the development of society based on the humanitarian spirit of “ai “(love) and “kei” (respect),which has been the Company motto since its inception, as the basis of corporate management, the Company operates its
businesses with its Vision of continually evolving, serving clients and society through global operations, and meeting their changing
needs. The Company discloses its management strategy and plan on the website and in securities report, etc.
(ii) Based on the Mission and the Vision mentioned in (i) above, the Company establishes continuous improvement of corporate
governance as its basic policy from the perspective of maintaining healthy corporate management and improving transparency aswell as efficiency of operations, supported by the view that sustainable improvement of corporate value is important to all
stakeholders.
(iii) Considering the financial results of the Company, the Board of Directors determines remuneration of directors within the total
remuneration approved at a General Meeting of Shareholders, in a way that it is linked to consolidated income before income taxes
and minority interests. The “Nominating and Remuneration Committee” which mainly consists of independent outside directors, firstreviews the details before the Board of Directors makes the decision. The Board of Directors works to ensure objectiveness,fairness and transparency by giving sufficient respect to its opinions.
(iv) When the Board of Directors elects executives and appoints candidates for directors and corporate auditors, the “Nominating
and Remuneration Committee” which mainly consists of independent outside directors, take measures, for instance, such as
interviewing candidates, to examine credentials and aptitude which would contribute to the improvement of corporate value in themedium and long term and to ensure the objectivity and fairness of any decision the Board of Directors makes. The Company has
the “Criteria for Independence of Outside Officers” independently in place for the election of outside directors and outside corporate
auditors and elects them in accordance with these Criteria.
[Principle 4-1. Roles and Responsibilities of the Board of Directors (1)]Supplementary Principle 4-1-1
The Board of Directors makes decisions about important matters stipulated by laws and regulations, the Articles of Incorporationand the Regulations for the Board of Directors such as basic management policies including formulation of a management plan,
preparation of an annual budget, and election of executive officers. Matters for resolution and matters to be reported at the Board of
Directors’ meetings are specifically stipulated in the Regulations for the Board of Directors.
[Principle 4-8. Effective Utilization of Independent Outside Directors]
Of nine incumbent directors of the Company, two are independent outside directors.
[Principle 4-9. Criteria for Independence and Qualification of Independent Outside Directors]
The Company has the “Criteria for Independence of Outside Officers” independently in place and posts them on its website(http://www.inabata.co.jp/english/governance/pdf/independence.pdf). In electing an outside director, the Company aims to appoint acandidate who has abundant experience and knowledge of corporate management, the ability to oversee decision-making andbusiness execution of the Board of Directors of the Company conducting businesses on a global basis, and the ability to provide
appropriate advice from an objective perspective.
[Principle 4-11. Prerequisite for Securing Viability of the Board of Directors and the Board of Corporate Auditors]
Supplementary Principle 4-11-1
The Company adopts an executive officer system and positions the Board of Directors as the decision-making body ofmanagement policies and strategies of the Company. The Company works to secure a reasonable number of directors in the Board of
Directors to enable swift decision-making. There are nine incumbent directors (six internal directors and three outside directors), ofwhom two are independent outside directors. In electing a new candidate for director, the Board of Directors makes a decision after
discussion by the “Nominating and Remuneration Committee” while considering the knowledge, experience and views of eachcandidate.
Supplementary Principle 4-11-2
The Company shall obtain the approval of the Board of Directors in accordance with the Regulations for the Board of Directors
when an internal director of the Company serves concurrently as a director or a corporate auditor of another company. The Company
shall obtain the approval of the Board of Corporate Auditors when an internal corporate auditor of the Company serves concurrently
as a director or a corporate auditor of another company.
In electing an outside director or an outside corporate auditor, the Company checks concurrent positions each candidate holds andfocuses on whether it is realistically possible for each candidate to perform the functions and duties required as an outside officer of
the Company.
The Company discloses the status of significant concurrent positions directors and corporate auditors hold in securities reports,
etc.
[Principle 4-14. Training of Directors and Corporate Auditors]
Supplementary Principle 4-14-2
When an internal director and an internal corporate auditor assume their posts, the Company provides opportunities to them tounderstand the legal obligations and roles and responsibilities that they are required to follow as director/corporate auditor. For
outside directors and outside corporate auditors, the Company provides opportunities to them to have meetings with generalmanagers of each internal division or office and for overseas visits/site visits as appropriate so that they can fully understand thebusinesses of the Group.
The Company provides opportunities to directors and corporate auditors for training after they assume their posts so that they canacquire the required knowledge and further understand their roles and responsibilities. The Company reimburses any director or
corporate auditor for any required expenses for training.
[Principle 5-1. Policy on Constructive Dialog with Shareholders]
The Company actively holds a dialog with shareholders and investors to contribute to sustainable growth of the Company andimprovement of the medium- and long-term corporate value.
The policy on development of a system which facilitates a constructive dialog with shareholders and investors and relevant efforts
are as follows:(1) IR System• Under the IR system of the Company, the President serves as the responsible person, and the director in charge of Financial
Management Office serves as a director in charge of IR. In principle, the President and the director in charge of IR lead a
dialog with shareholders and investors.
• There is a section dedicated to IR (IR Department) within the Financial Management Office which serves as a contact point forshareholders and investors.
• The IR Department has a system in place for the collection/analysis of various management information and timely andadequate information provision by collaborating with relevant divisions such as the Financial Management Office, the General2

Affairs Office and sales divisions.
(2) IR Activities• The Company handles requests for individual meetings in a positive manner to a reasonable extent.
• The Company holds a briefing on financial results twice a year to explain the progress of the mid-term business plan andoverview of financial results.
• The Company creates an occasion for a dialog with individual shareholders and investors through participation in IR events,
etc.
• The Company actively works to provide information through its website, company brochure, shareholder news and notices ofGeneral Meeting of Shareholders and so forth.
• The Company creates opportunities for dialog with shareholders and investors abroad by holding IR events overseas.
(3) Feedback• For matters for which feedback seems necessary in a dialog, the director in charge of IR reports them to the Board of Directors
to share and use them as reference.
(4) Management of Insider Information• The Company carries out thorough control of insider information in accordance with the “Rules for Information Disclosure,” oneof the internal rules. In addition, the Company establishes a period between the day after each quarterly closing date and theannouncement date as a silent period.
(5) Understanding of Shareholder Structure• The Company conducts shareholder identification twice a year in principle to understand the holding of the Company’s sharesby substantial shareholders.

2. Capital Structure
Foreign Shareholding Ratio

From 20% to less than 30%[Status of Major Shareholders] Update
Name / Company Name
Sumitomo Chemical Company, Limited
Japan Trustee Services Bank, Ltd. (Trust Account)
JP MORGAN CHASE BANK 385093
The Master Trust Bank of Japan, Ltd. (Trust Account)
Mizuho Trust & Banking Co., Ltd. Employee Pension Trust (Mizuho Bank account),
Re-trust Trustees, Trust & Custody Services Bank, Ltd.
CBNY DFA INTL SMALL CAP VALUE PORTFOLIO
Katsuo Inabata
Japan Trustee Services Bank, Ltd. (Trust Account 9)
Mizuho Bank, Ltd.
Maruishi Chemical Trading Co., Ltd.

Controlling Shareholder (except for
Parent Company)―――

Parent Company

N/A

Number of
Shares Owned
13,836,000
3,963,900
3,191,400
2,298,100

Percentage (%)
21.79
6.24
5.03
3.62

1,736,000

2.73

1,346,200
1,161,400
1,119,000
1,114,900
961,600

2.12
1.83
1.76
1.76
1.51

Supplementary Explanation―――

3. Corporate Attributes
Listed Stock Market and Market Section

First Section of the Tokyo Stock Exchange

Fiscal Year-End

MarchType of Business

Wholesale trade

Number of Employees (consolidated) as of
the End of the Previous Fiscal Year

1,000 or more

Net sales (consolidated) for the Previous
Fiscal Year

From ¥100 billion to less than ¥1 trillion

Number of Consolidated Subsidiaries as of
the End of the Previous Fiscal Year

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―――3II. Business Management Organization and Other Corporate Governance Systems regarding
Decision-making, Execution of Business, and Oversight in Management
1. Organizational Composition and Operation
Organization Form

Company with Board of Corporate Auditors[Directors]
Maximum Number of Directors Stipulated
in Articles of Incorporation
Term of Office Stipulated in Articles ofIncorporation

14 directors
1 yearChairperson of the Board

President

Number of Directors

9 directors

Appointment of Outside Directors

Appointed

Number of Outside Directors

3 directors

Number of Independent Officers
Designated from among Outside
Directors

2 directors

Outside Directors’ Relationship with the Company (1)
Name

*
*
*
a
b
c
d
e
f
g
h
i
j
k

Relationship with the Company (*)

AttributeaMitsunori Takahagi

From another company

Yoshimasa Takao

From another company

Katsumi Nakamura

From another company

b

c

d

e

f

g

h

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 thepast“●” when a close relative of the director presently falls or has recently fallen under the category; “▲”when a close relative of thedirector fell under the category in the past
Executive (meaning a person who executes business; hereinafter, the same) of the Company or its subsidiaries
Executive or non-executive director of a parent company of the Company
Executive of a fellow subsidiary company of the Company
A party whose major client or supplier is the Company or an executive thereof
Major client or supplier of the Company or an executive thereof
Consultant, accountant or legal professional who receives a large amount of monetary consideration or other property from theCompany in addition to remuneration as a director/corporate auditor
Major shareholder of the Company (or an executive of the said major shareholder if the shareholder is a corporation)
Executive of a client or supplier company of the Company (which does not correspond to any of d, e, or f) (the outside director
himself/herself only)
Executive of a company, with which outside directors/corporate auditors are mutually appointed (the outside director
himself/herself only)
Executive of a company or organization that receives a donation from the Company (the outside director himself/herself only)
Others

Outside Directors’ Relationship with the Company (2) Update
Name

Mitsunori Takahagi

Designation as
Independent Officer○

Supplementary Explanationof the Relationship

Reasons for Appointment
Mitsunori Takahagi has served as
President and Representative Director ofJapan Energy Corporation, President andRepresentative Director of Nippon Mining
Holdings, Inc., and President andRepresentative Director, and President andExecutive Officer of JX Holdings, Inc.
Currently he serves as Counselor to JX
Holdings, Inc.
In electing an outside director, theCompany aims to appoint a candidate who
has abundant experience and knowledge ofcorporate management, the ability tooversee the decision-making and businessexecution of the Board of Directors of theCompany, which conducts business on a
global basis, and is capable of providing
appropriate advice from an objective
perspective.
As he possesses abundant experience―4

as a senior executive in a leading company
in the energy, resources, and materials
industry, the Company considers him
suitably qualified and appoints him as
outside director.
As he satisfies the requirements of the
independence standards stipulated by the
Tokyo Stock Exchange as well as the“Criteria for Independence of Outside
Officers” separately established by theCompany, the Company appoints him as
independent officer.

―

Yoshimasa Takao has served as
Representative Director and Senior
Managing Executive Officer of Sumitomo
Chemical Co., Ltd. and Representative
Director, Vice President, and Executive
Officer of the same company.
He currently serves as Executive Deputy
Chairman of the same company.
In electing an outside director, theCompany aims to appoint a candidate who
has abundant experience and knowledge ofcorporate management, the ability tooversee the decision-making and businessexecution of the Board of Directors of theCompany, which conducts business on a
global basis, and is capable of providing
appropriate advice from an objective
perspective.
As he possesses abundant experience
as a senior executive of a generalchemicals manufacturer and holds
extensive knowledge of the chemicals
industry, the Company considers him
suitably qualified and appoints him as
outside director.

―

Katsumi Nakamura has served as Vice
President of Renault (France) and as
Director of NISSAN MORTOR CO., LTD.
He currently serves as Chairman of theBoard of Calsonic Kansei Corporation.
In electing an outside director, theCompany aims to appoint a candidate who
has abundant experience and knowledge ofcorporate management, the ability tooversee the decision-making and businessexecution of the Board of Directors of theCompany, which conducts business on a
global basis, and is capable of providing
appropriate advice from an objective
perspective.
As he has abundant experience as asenior executive of large global
corporations, the Company considers him
suitably qualified and appoints him as
outside director.
As he satisfies the requirements of the
independence standards stipulated by the
Tokyo Stock Exchange as well as the“Criteria for Independence of Outside
Officers” separately established by theCompany, the Company appoints him as
independent officer.

Yoshimasa Takao

Katsumi Nakamura○

Voluntary Establishment of Committee(s)Corresponding to Nominating Committee orRemuneration Committee
UpdateEstablished

Committees Voluntarily Established, Composition, and Chairperson’s Attributes Update

Committee
Corresponding toNominating
Committee
Committee
Corresponding to
Remuneration
Committee

Committee’s
Name

All
Committee
Members

Full-timeMembers

Internal
Directors

OutsideDirectors

OutsideExperts

Nominating andRemuneration
Committee

3

0

1

2

0

0

Internal
Director

Nominating andRemuneration
Committee

3

0

1

2

0

0

Internal
Director

5

Other

Chairperson

Supplementary Explanation Update
When the Board of Directors elects senior executives and appoints candidates for directors and corporate auditors, the“Nominating and Remuneration Committee” which mainly consists of independent outside directors takes measures, for instance,such as interviewing candidates, to examine credentials and aptitude which would contribute to the improvement of corporate value inthe medium and long term. The Board of Directors also reviews these matters in determining the remuneration of directors.
The Board of Directors works to ensure objectiveness, fairness and transparency by giving sufficient respect to its opinions.

[Corporate Auditors]
Establishment of Board of Corporate Auditors

Established

Maximum Number of Corporate Auditors Stipulated
in Articles of Incorporation

No limit on the number of corporate auditors

Number of Corporate Auditors

4 corporate auditors

Cooperation among Corporate Auditors, Accounting Auditor and the Internal Audit
Corporate auditors, the accounting auditor and the Internal Audit Office collaborate with one another on a regular basis throughreporting of audit results and consultation.
Appointment of Outside Corporate
Auditors

Appointed

Number of Outside Corporate Auditors

3 auditors

Number of Independent Officers
Designated from among Outside
Corporate Auditors

3 officers

Outside Corporate Auditors’ Relationship with the Company (1)Name
Shuichi Suzuki
Yasuji Matsuyama
Yoshitaka Takahashi

Relationship with the Company (*)

Attribute

a

b

c

d

e

f

g

h

i

j

k

l

m

Attorney
Certified Public Accountant
From another company**

Categories for “Relationship with the Company””○” when the corporate auditor presently falls or has recently fallen under the category; “△” when the corporate auditor fell under
the category in the past
* “●” when a close relative of the corporate auditor presently falls or has recently fallen under the category; “▲”when a close relativeof the corporate auditor fell under the category in the pasta
Executive (meaning a person who executes business; hereinafter, the same) of the Company or its subsidiariesb
Non-executive director or accounting advisor of the Company or its subsidiariesc
Executive or non-executive director of a parent company of the CompanydCorporate auditor of a parent company of the Company
eExecutive of a fellow subsidiary company of the Companyf
A party whose major client or supplier is the Company or an executive thereofgMajor client or supplier of the Company or an executive thereofhConsultant, accountant or legal professional who receives a large amount of monetary consideration or other property from theCompany in addition to remuneration as a director/company auditori
Major shareholder of the Company (or an executive of the said major shareholder if the shareholder is a corporation)j
Executive of a client or supplier company of the Company (which does not correspond to any of f, g, or h) (the outside corporate
auditor himself/herself only)k
Executive of a company, with which outside directors/corporate auditors are mutually appointed (the outside corporate auditor
himself/herself only)l
Executive of a company or organization that receives a donation from the Company (the outside corporate auditor
himself/herself only)m
Others6

Outside Corporate Auditors’ Relationship with the Company (2) Update
Designation as
Independent Officer

Name

Shuichi Suzuki

Supplementary Explanationof the Relationship

○

―

○

―

○

―

Reasons for Appointment
Shuichi Suzuki is an attorney, andthe Company appoints him as outside
corporate auditor for the purpose of
conducting an objective, proactive andfair audit from the perspective of aprofessional.
As he satisfies the requirements of
the independence standards stipulatedby the Tokyo Stock Exchange as wellas the “Criteria for Independence ofOutside Officers” separately
established by the Company, theCompany appoints him as independent
officer.
Yasuji Matsuyama is a certified public
accountant, and the Company appoints
him as outside corporate auditor for the
purpose of conducting an objective,
proactive and fair audit from theperspective of a professional.
As he satisfies the requirements of
the independence standards stipulatedby the Tokyo Stock Exchange as wellas the “Criteria for Independence ofOutside Officers” separately
established by the Company, theCompany appoints him as independent
officer.
Yoshitaka Takahashi has served as acorporate auditor of a listed company,
and the Company appoints him as
outside corporate auditor for the
purpose of conducting an objective,
proactive and fair audit by utilizing his
abundant experience and broad views.
As he satisfies the requirements of
the independence standards stipulatedby the Tokyo Stock Exchange as wellas the “Criteria for Independence ofOutside Officers” separately
established by the Company, theCompany appoints him as independent
officer.

Yasuji Matsuyama

Yoshitaka Takahashi[Independent Officers]
Number of Independent Officers

5 officers

Other Matters Related to Independent Officers
The Company designates all outside officers who satisfy the requirements of independent officers as such.

[Incentives]
Incentive Policies for Directors Update

Performance-linked remuneration system

Supplementary Explanation Update
Considering the financial results of the Company, the Board of Directors determines remuneration of directors within the total
remuneration approved at a General Meeting of Shareholders, in a way that it is linked to consolidated income before income taxes
and minority interests .
Recipients of Stock Options

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

No disclosure of individual remuneration

7

Supplementary Explanation
Total remuneration paid to directors during the previous fiscal year of the Company (from April 1, 2014 to March 31, 2015) is 312
million yen.
Policy on Determining Remuneration
Amounts and Calculation Methods Update

Established

Disclosure of Policy on Determining Remuneration Amounts and Calculation Methods
By considering the financial results of the Company The Board of Directors determines remuneration of directors within the total
remuneration approved at a General Meeting of Shareholders, in a way that it is linked to consolidated income before income taxes
and minority interests.

[Supporting System for Outside Directors (Outside Corporate Auditors)]
The Corporate Secretariat Department of the General Affairs Office is responsible for supporting outside directors and outside
corporate auditors and handles administrative communications, etc.

2. Matters on Functions of Business Execution, Auditing, Oversight, Nominating and Remuneration
Decisions (Overview of Current Corporate Governance System) Update[Board of Directors]
The Board of Directors, as the decision-making body of management policies and strategies of the Company, currently consists ofnine directors and performs its decision-making function for corporate management by holding a regular monthly meeting and ad hoc
meetings.
The Company adopts an executive officer system. This is to improve the efficiency of corporate management and the speed ofdecision-making by clearly separating directors as members of the Board of Directors performing the decision-making function forcorporate management from executive officers performing the business execution function and enhancing/activating each function, inorder to swiftly and appropriately respond to changes in the management environment. Currently, there are 12 executive officers ofwhom six serve concurrently as directors.
Of the directors, three are outside directors. Outside directors, with their abundant experience and broad views as top executives,
oversee the decision-making of the Board of Directors and business execution by executive officers and provide expert opinions froman objective standpoint.
[Nominating and Remuneration Committee]
The “Nominating and Remuneration Committee” which mainly consists of independent outside directors is currently made up of
two independent outside directors and one internal director.
When the Board of Directors elects executives and appoints candidates for directors and corporate auditors, the “Nominating andRemuneration Committee” takes measures, for instance, such as interviewing candidates, to examine credentials and aptitude which
would contribute to the improvement of corporate value in the medium and long term. The Board of Directors reviews these matters indetermining the remuneration of directors.
The Board of Directors works to ensure objectiveness, fairness and transparency by giving sufficient respect to its opinions.
[Corporate Auditors]
The Company adopts a corporate auditor system. The Board of Corporate Auditors consists of four corporate auditors andconducts an audit of the decision-making of the Board of Directors and business execution of directors.
Of the corporate auditors, three are outside corporate auditors. Outside corporate auditors, with their expertise in finance,accounting and law, etc. and possessing a high degree of independence, oversee decision-making of the Board of Directors anddirectors’ execution of duties. Specific efforts for enhancement of the functions of corporate auditors are described in “Cooperation
among Corporate Auditors, Accounting Auditor and the Internal Audit,” “Appointment of Outside Auditors,” and “Supporting System for
Outside Directors (Outside Corporate Auditors).”[Accounting Auditor]
The accounting auditor of the Company is KPMG AZSA LLC. Certified public accountants who performed account closing
operations for the fiscal year ended March 2015 are Koichi Inoue (designated limited partner), Katsumi Hashimoto (designated limited
partner) and Masaya Kuze (designated limited partner). There are eight certified public accountants and eight staff members serving
as assistants for audit work. Fees (less consumption tax) for the work stipulated by Article 2, Paragraph 1 of the Certified Public
Accountants Act (Act No. 103 of 1948) paid to KPMG AZSA LLC total 76 million yen and all other fees (less consumption tax) total 0
million yen.

3. Reasons for Adoption of Current Corporate Governance System
The Company believes that the most suitable corporate governance system has been established by adopting a system of audit bycorporate auditors including several outside corporate auditors possessing a high degree of expertise and independence on decision
making from the Board of Directors’ meetings attended by outside directors, who have broad views and expertise, as well as businessexecution of executive officers.

8III. Implementation of Measures for Shareholders and Other Stakeholders
1. Measures to Vitalize the General Meeting of Shareholders and Smooth Exercise of Voting Rights

UpdateSupplementary Explanation
Early Notification of General Meeting of
Shareholders

The Company annually sends a notice approximately three weeks prior to the dateof a General Meeting of Shareholders. On June 2, 2015, the Company sent a notice ofthe 154th Ordinary General Meeting of Shareholders held on June 24, 2015.

Allowing Electronic Exercise of Voting Rights

Voting rights of the Company may be exercised via the Internet through computer ormobile phone.

Efforts for Improvement of Environment for
Exercise of Voting Rights by Institutional
Investors such as Participation in the Platform
for Electronic Exercise of Voting Rights

The platform for electronic exercise of voting rights for institutional investors
managed by Investors Communications Japan, Inc. is available.

OthersPrior to the sending of a notice of the General Meeting of Shareholders on June 2,
2015, the Company posted it on its Japanese website(http://www.inabata.co.jp/investor/pdf/notification_150624.pdf) on May 29, 2015.

2. IR Activities Update
Supplementary Explanation

Explanation byRepresentative

Preparation and Announcement ofDisclosure Policy

The Company has a policy on information disclosure in place and isposted it on its website(http://www.inabata.co.jp/english/company/csr/compliance/).

Regular Investor Briefings for Individual
Investors

The Company provided one briefing on company information for the
fiscal year ended March 2015.

Not
Established

Regular Investor Briefings for Analysts andInstitutional Investors

The Company provides financial results meetings for analysts andinstitutional investors twice a year in the second quarter and at fiscal year
end.

Established

Regular Investor Briefings for Overseas
Investors

The Company holds individual meetings on site for overseas investors
in Europe, the US, and Asia.

Established

Posting of IR Materials on Website
Establishment of Department and/or Person
in Charge of IR

The Company posts IR materials on its website(http://www.inabata.co.jp/english/investor/index.html) such as financial
results, information subject to timely disclosure other than financial results,
operation overview/shareholder news, securities reports, semiannual
reports, quarterly reports, and company brochure.
The IR Department of the Financial Management Office is in charge of
IR at the Company.

3. Measures to Ensure Due Respect for Stakeholders
Supplementary Explanation
Formulation of Policies for Provision ofInformation to Stakeholders

The Company has a policy on information disclosure in place and has posted it on its
website (http://www.inabata.co.jp/english/company/csr/compliance/).

9IV. Matters Related to Internal Control System
Update(Basic Views on Internal Control System and the Progress of System Development)
At the Board of Directors’ meeting held on April 30, 2015, the Basic Policy on Development and Improvement of the Internal
Control System was partially revised based on the Companies Act and the Ordinance for Enforcement of the Companies Act which
took effect on May 1, 2015, and a resolution was passed for the following items.
1. System to Ensure that Performance of Duties by Directors and Employees Complies with Laws and Regulations as well as the
Articles of Incorporation(1) “Company’s motto,” “Mission,” “Vision,” and “IK Values” shall be established.
(2) Directors or executive officers shall be appointed as persons in charge of internal control and an Internal Control Committee
shall be established.
(3) Directors or executive officers shall be appointed as persons in charge of compliance and a Compliance Committee shall beestablished.
(4) Directors or executive officers shall be appointed as persons in charge of internal audits and an Internal Audit Office shall beestablished.
(5) Directors or executive officers shall be appointed as persons in charge of personal information protection and a system toensure compliance with the Act on the Protection of Personal Information shall be established.
(6) An internal whistle blowing system shall be established, reports shall be received on incidents of violations of compliance, anda system to protect internal whistle blowers shall be established.
(7) A director who has discovered an incident of a violation of compliance shall report to other directors and corporate auditors in atimely manner.
(8) A corporate auditor who has recognized problems with the operation of compliance system or internal whistle blowing systemshall state opinions and request improvements.
(9) Matters relating to office regulations and disciplinary action shall be established in the Rules of Employment, and measures
shall be taken to ensure the execution of duties by employees comply with laws and regulations and the Articles ofIncorporation.

1. Basic Views on Internal Control System and the Progress of System Development

2. System to Store and Manage Information on Performance of Duties by Directors of the Company
For performance of duties by directors, reports are made at the Board of Directors’ meeting, and the contents are recorded in theminutes of such meeting, which are properly stored and managed. Moreover, other records concerning the performance of duties areproperly stored and managed in accordance with the Rules for Document Management.
3. System Including Rules for Management of the Risk of Loss of the Company
For the risk of loss of the Company, the rules for the management of each risk (including systems) are established andappropriately implemented by the office in charge of supervising matters relating to the risk of loss for each risk category (risks suchas finance, legal affairs, environment, quality, credit and natural disaster, etc.).
4. System to Ensure that Duties are Performed Efficiently by Directors of the Company(1) The Board of Directors’ meetings will be held regularly, in principle once a month and ad hoc meetings shall be held asnecessary.
(2) The Keiei Kaigi(advisory panel on various systems) and The Shinsa Kaigi (organization which reviews credit and individual
important cases) consisting of directors and corporate auditors discuss important matters for the Company’s management
policies and strategies prior to submitting such matters to the Board of Directors.
(3) The omission of resolutions at the Board of Directors’ meeting (approval by documents) is provided for in the Articles ofIncorporation to promote efficiency.
(4) Decision criteria are established to promote efficiency of performance of duties by directors by delegating authority.
5. System to Ensure Appropriateness of Operations of Inabata Group(the Group)(1) Efforts shall be taken for all officers and employees of the Group to familiarize themselves with “Corporate Principle,”“Management Philosophy ;Mission,” “Vision,” and “IK Values” of the Company.
(2) Directors and employees of the Company shall be dispatched to subsidiaries as necessary as officers.
(3) Subsidiaries shall be under obligation to report sales results, financial position and other important information to the Company
on a regular basis in accordance with the Rules for Group Company Management. Moreover, concerning important mattersarising at subsidiaries, subsidiaries shall be under obligation to seek permission from the Company beforehand and receive
approval for the matter.
(4) An organization to oversee subsidiaries shall be established, and such organization shall have a system established tosupervise and guide the subsidiaries’ management.
(5) Internal audits of the subsidiaries shall be conducted in accordance with the Rules for Internal Audits.
(6) The internal whistle blowing system of the Company shall have a system established to enable whistle-blowing by officers or
employees of subsidiaries.
6. System Relating to Employees Assisting Corporate Auditors’ Duties
Upon a request from a corporate auditor for the Company to place an employee to assist with his/her duties, internal rules
containing the following content shall be established and an appropriate appointee who is independent from directors shall be
appointed.
(1) An employee assisting a corporate auditor shall perform his/her duties under the direction of the corporate auditor.
(2) Appointment, transfer, personnel evaluation, wages, disciplinary action of the employee assisting a corporate auditor shall be
determined after obtaining the approval of the Board of Corporate Auditors (or if the Board of Corporate Auditors has
nominated a specified corporate auditor, the said corporate auditor).
(3) When selecting the employee assisting a corporate auditor, ample consideration shall be given to that employee’s experience,
knowledge and leverage, taking into account the important role that constitutes one part of the audit function.
(4) The directors and employees shall not unreasonably restrict the execution of duties of the employee assisting a corporate
auditor.
7. System for Report to Corporate Auditors
To provide a system for reporting to corporate auditors, internal company rules providing for the following content will beestablished and appropriately put into operation.
(1) Officers and employees of the Group shall make prompt and appropriate reports when the Company’s corporate auditors haverequested a report on matters relating to the execution of business.
(2) Officers and employees of the Group shall provide reports to the Company’s corporate auditors or Board of Corporate Auditors
whenever deemed appropriate when the Group has incurred significant loss or is at risk thereof.
(3) Departments inside the Group that have the management responsibility for internal audits, compliance, risk management,
subsidiary management, and so forth shall conduct report meetings at the Board of Corporate Auditors on a regular basis or as

10deemed necessary.
(4) The department in charge of the internal whistle blowing system of the Company shall report to the Company’s corporate
auditors on a regular basis on the status of whistle-blowing incidents from officers or employees of the Group.
(5) Officers and employees of the Group shall be forbidden from treating a person who reported information to a corporate auditor
disadvantageously because of such action.
8. Other Systems to Ensure that Audits by Corporate Auditors are Conducted Effectively(1) The representative director shall hold meetings with corporate auditors on a regular basis, and at such meetings, opinions
shall be exchanged on management policies, issues that require the Company’s action, major risks surrounding the Company,
the status of establishment and operation of internal controls in the Group, the provision of environments for audits by the
corporate auditor and important issues concerning audits.
(2) When a corporate auditor requests the assistance of a lawyer, certified accountant or other outside professional to assist in theexecution of his/her duties, or claims for the cost required to commission investigations, appraisals, or other professional
services, the Company shall not be in a position to refuse these requests except in cases when the costs related to theaforesaid claims are deemed not to be necessary for the corporate auditor’s execution of duties.
(Status of Development and Improvement of Risk Management System)
Of risks which may affect the Company, credit risk of business partners and risk for legal regulations are monitored and overseenby the Risk Management Office. In order to avoid risk for legal regulations, the Company appropriately receives advice from six
lawyers with whom the Company signs an advisory contract.

2. Basic Views on Eliminating Anti-Social Groups and the Progress of Related Efforts
In the “Declaration of Compliance Inabata & Co., Ltd.,” the Company declares that “We never give in to antisocial groups, we
refuse unreasonable demands and avoid easy monetary compromises.” In addition, in order to work on the elimination of anti-socialgroups on a company-wide basis, the Company posts the “Declaration of Compliance Inabata & Co., Ltd.” as well as the Compliance
Guideline on its internal website and holds training sessions on compliance to keep officers and employees of the Company informed
about the importance of eliminating anti-social groups.
The General Affairs Department of General Affairs Office is in charge of handling responses to anti-social groups and a manual isestablished to respond to a situation. In addition, the Company collects information on anti-social groups in collaboration with theanti-organized crime section of the Metropolitan Police Department and Tokuboren (association of special violence prevention
measures) under the authority of the Metropolitan Police Department .
The “Declaration of Compliance Inabata & Co., Ltd.” is available on its website(http://www.inabata.co.jp/english/company/csr/compliance/).

11

V. Other
1. Adoption of Anti-Takeover Measures
Adoption of Anti-Takeover Measures

EstablishedSupplementary Explanation
1. Basic Policy on Party Which Controls Decisions on Financial and Business Policies of the Company
When a specified party tries to make a large-scale purchase whose purpose is to acquire shares of the Company which gives suchbuyer the power to influence decisions on financial and business policies of the Company, the Company believes the decision ofwhether to sell shares should be left to the judgment of shareholders of the Company.
However, the Company as a group has 55 subsidiaries and 13 associates at home and abroad across Japan, Southeast Asia,
Northeast Asia, the Americas and Europe, operating a wide variety of businesses mainly consisting of manufacturing and sale ofproducts in areas such as IT & Electronics, Chemicals, Life Industry, Plastics, Housing & Eco Materials and others. For the
management of the Company, extensive knowhow, abundant experience and the sufficient understanding of relations built withcustomers/employees and business partners (stakeholders) at home and abroad are essential. If a party which controls decisions on
financial and business policies of the Company lacks sufficient understanding of these matters, shareholder value that can berealized in the future may be undermined.
When a large-scale purchase is suddenly made, it is essential that both the buyer and the Board of Directors of the Company
provide adequate and sufficient information so that shareholders can make a proper judgment within a short time on whether the priceof acquisition of the Company’s shares proposed by the buyer is reasonable. Furthermore, even for shareholders who consider
continuing to hold the Company’s shares, details of the management policy and business plans such buyer considers whenparticipating in the management of the Company (effect of such large-scale purchase on the Company, policy on relations withstakeholders of the Company such as employees, affiliates, customers and business partners) are important information in making adecision on whether to retain such shares. Similarly, the Company believes the opinion of the Board of Directors on such large-scalepurchases is also important information for shareholders of the Company for making a decision.
Accordingly, for a large-scale purchase whose purpose is to acquire the Company’s shares which gives a buyer the power toinfluence decisions on financial and business policies of the Company, the Company believes such buyer should, to support the
judgment of shareholders, provide necessary and sufficient information on such purchase to the Board of Directors of the Company inadvance and begin such purchase only after a certain evaluation period in accordance with certain rules established and disclosed inadvance by the Company (hereinafter called the “Rules for Large-Scale Purchase”).
Of large-scale purchases, there may be one whose obvious purpose is misuse and which would consequently cause irreparable
damage to the Company and thus significantly undermine the benefit of all shareholders of the Company. The Company believes it isnecessary for the protection of the interests of all shareholders of the Company that the Board of Directors takes appropriate
measures against such purchase in accordance with the Rules for Large-Scale Purchase. As of March 31, 2015, Sumitomo ChemicalCo., Ltd. is the largest shareholder of the Company, owning 21.79% of the issued shares. Since the Company became the general
distributor in Japan of pharmaceutical products manufactured by Sumitomo Chemical Co., Ltd. in July 1944, the Company has
maintained good relations with Sumitomo Chemical Co., Ltd. However, given the fact that the shareholder structure may change witha potential increase in liquidity of the Company’s shares due to share transfer by shareholders and that the shareholding ratio of
Sumitomo Chemical Co., Ltd. may decrease as a result of new financing from capital markets for future business expansion, it ispossible that a large-scale purchase which undermines the benefit of all shareholders of the Company (defined below) may be made.
2. Effective Utilization of Assets, Formulation of Appropriate Corporate Group and Special Efforts Contributing to Realization of Other
Basic Policies
As special efforts contributing to realization of the Basic Policy mentioned in 1. above, the Company works on the following efforts.
(1) Further expansion and deepening of overseas businesses(2) Focus on markets with growth potential and undeveloped areas(3) Development and expansion of infrastructure for global operation(4) Investment for future growth(5) Further pursuit of efficiency of fund operations/asset efficiency and enhancement of financial standing(6) Continuous development of global human resources
As the above-mentioned efforts are intended to improve the Group’s market value and thus reduce the risk of the emergence of alarge-scale buyer (defined below) which would significantly undermine the interests of all shareholders of the Company, the Company
believes they are in keeping with the Basic Policy on control over the Company described above. As such efforts are intended to
improve the Group’s value, it is clear that they do not undermine the common interests of shareholders of the Company and do not
aim to maintain the position of officers of the Company.
3. Efforts to Prevent Control by Inappropriate Parties of Decisions on Financial and Business Policies of the Company According to
the Basic Policy(1) Details of Efforts to Prevent Control by Inappropriate Parties on Decisions on Financial and Business Policies of the Company
According to the Basic Policy
As efforts to prevent control by inappropriate parties over decisions on financial and business policies of the Company, according to
the Basic Policy as mentioned in 1. above, the Company has established the Rules for Large-Scale Purchase applicable to apurchase of share certificates of the Company for the purpose of making the ratio of voting rights of a certain shareholder group 20%
or higher, or to a purchase of share certificates of the Company which results in a ratio of voting rights of a certain shareholder groupof 20% or higher (in either case, excluding a purchase the Board of Directors of the Company approves in advance, regardless of
specific methods of purchase, such as market trade or tender offer; such purchase is hereinafter called a “large-scale purchase” while
such buyer is called a “large-scale buyer”) and stipulates a policy on how to handle cases where a large-scale buyer complies with therules and where a large-scale buyer does not comply (hereinafter called the “Policy on Handling of Large-Scale Purchase”).
(2) Fact that the Policy on Handling of Large-Scale Purchase is in accord with the Basic Policy, Does Not Undermine the Common
Interests of Shareholders and Does Not Aim to Maintain the Position of Company Officers and Reasons Thereof
i. Fact that the Policy on Handling of Large-Scale Purchase Keeps with the Basic Policy
The Policy on Handling of Large-Scale Purchase stipulates details of the Rules for Large-Scale Purchase, the policy of how tohandle a case of actual large-scale purchase, establishment of an independent committee and effects on shareholders and investors,
etc.
The Policy on Handling of Large-Scale Purchase requires a large-scale buyer to provide necessary and sufficient information on alarge-scale purchase to the Board of Directors of the Company in advance and start such purchase only after a certain evaluation
period, and specifies that the Board of Directors of the Company would take appropriate countermeasures against a large-scalebuyer who fails to comply with these rules.
In addition, the Policy stipulates that when the Rules for Large-Scale Purchase are followed but the Board of Directors of theCompany considers a large-scale purchase made by a large-scale buyer significantly undermines the interests of all shareholders of
the Company, the Board of Directors of the Company may take appropriate countermeasures against such large-scale buyer in order12to protect the interests of all shareholders of the Company.
As such, the Policy on Handling of Large-Scale Purchase is designed in keeping with the idea of the Basic Policy on control over
the Company.
ii. Fact that the Policy on Handling of Large-Scale Purchase Does Not Undermine the Common Interests of Shareholders
As mentioned in 1. above, the Basic Policy on control over the Company is based on the premise that the common interests ofshareholders of the Company is respected. The Policy on Handling of Large-Scale Purchase is designed in line with the idea of the
Basic Policy on control over the Company and aims to provide information necessary for shareholders of the Company to decide
whether to accept a large-scale purchase, offer opinions of the Board of Directors of the Company and guarantee an opportunity toreceive an alternate proposal. The Company believes that the Policy on Handling of Large-Scale Purchase contributes to thecommon interests of shareholders of the Company rather than undermining it.
Furthermore, the Policy on Handling of Large-Scale Purchase is valid for three years, and its effectuation and extension require theapproval of the shareholders of the Company. The Policy expires if its extension is not approved at a General Meeting of
Shareholders, and a General Meeting of Shareholders of the Company or the Board of Directors consisting of directors elected by aGeneral Meeting of Shareholders may abolish the Policy before its expiration date. The Policy on Handling of Large-Scale Purchaseis not a dead-hand type of takeover defense measure (i.e., an anti-takeover measure which cannot be stopped even when a majorityof members of the Board of Directors are replaced) or a slow-hand type of takeover defense measure (i.e., an anti-takeover measure
which takes time to stop as members of the Board of Directors cannot be replaced simultaneously). These guarantee that the Policy
on Handling of Large-Scale Purchase does not undermine the common interests of shareholders of the Company.
iii. Fact that the Policy on Handling of Large-Scale Purchase Does Not Aim to Maintain the Position of Company Officers
The Policy on Handling of Large-Scale Purchase is based on the fundamental principle that whether to accept a large-scalepurchase should be left up to judgment of shareholders of the Company, requests compliance with the Rules for Large-Scale
Purchase and invokes countermeasures, in order to protect the interests of all shareholders of the Company. The Policy on Handlingof Large-Scale Purchase discloses in advance and in detail a case where the Board of Directors of the Company invokescountermeasures, and such countermeasures are exercised by the Board of Directors of the Company in accordance with the rules of
the Policy.
When the Board of Directors of the Company assesses, examines and forms its opinions of a large-scale purchase, submits analternative proposal, negotiates with a large-scale buyer or invokes countermeasures, the Board of Directors shall take advice fromindependent outside experts, consult the independent committee consisting of members who are independent of the management
team engaged in the business execution of the Company, and respect recommendations from this committee to the extent possible.
In addition, when recommendations are issued by the independent committee in invoking countermeasures against a large-scalepurchase, the Company shall confirm the intention of the Company’s shareholders concerning whether to invoke suchcountermeasures. As such, the Policy on Handling of Large-Scale Purchase includes procedures to ensure proper management by
the Board of Directors of the Company.
Based on the above-mentioned overview, it is clear that the Policy on Handling of Large-Scale Purchase does not aim to maintainthe position of officers of the Company.

2. Other Matters Related to Corporate Governance System
The Company received ISO14001 certification in June 2000 and ISO9001 certification in April 2005 to improve customer
satisfaction. The Company consolidated the management system of ISO14001 and ISO9001 in November 2005 to ensure more
efficient and effective operation and works to maintain and manage it.
In addition to improvement of customer satisfaction, the Company has made efforts on a company-wide basis for BPR (Business
Process Reengineering) activities which fundamentally review and redesign all business processes of the Company in order todramatically reinforce the risk management capabilities and improve efficiency of operations.
From now on, the Company will work to develop and enhance the corporate governance system in order to improve satisfaction of
all stakeholders through establishment, maintenance and improvement of the internal control system responding to the internal
control reporting system based on the Companies Act and the Financial Instruments and Exchange Act.
(Overview of Timely Disclosure System)
1. Internal System for Timely Disclosure of Company Information
The Company discloses matters required by law and company information to stakeholders, including shareholders and investors,
on a timely basis via its website and other means of communication including various printed materials. The means for information
communication are as follows.
The Financial Management Office collects requests for approval (matters presented based on the Rules for Request for Approval)presented by each division (including subsidiaries), matters presented and approved by the Shinsa Kaigi (organization which reviews
credit and individual important cases) and the Keiei Kaigi (advisory panel on various systems) and significant facts reported byvarious reports, and determines whether such items are subject to disclosure. When such items are subject to disclosure, the person
responsible for information disclosure formulates a plan for the disclosure statement. Subsequently, the President submits an original
proposal of disclosure statement to the Board of Directors, the approval body, to obtain approval, and then the Financial Management
Office discloses information.
2. Check Function of Internal System for Timely Disclosure
The Legal Department of Risk Management Office (office in charge), the General Affairs Office and the Financial Management
Office (main consulted parties) check requests for approval and reports presented, and verify their accuracy. For matters presented to
the Shinsa Kaigi and the Keiei Kaigi, the Legal Department of Risk Management Office (office in charge) and the General Affairs
Office, as well as the Shinsa Kaigi and the Keiei Kaigi check the accuracy.

13

The chart of the corporate governance system of the Company is as below.

Election/Dismissal
Board of Corporate Auditors

Collaboration

General meeting of shareholders
Election/Dismissal

Election/Dismissal

Accounting Auditors(Four corporate auditors of whom three areoutside auditors)

Collaboration
Audit

Audit
Board of Directors(Nine directors of whom three are outside directors)

Consult

Collaboration

AdviceNominating andRemuneration
Committee(Three directors of whom
two are outside directors)

President

Compliance Committee
Internal Audit
OfficeInternal Control Committee
Human Rights Affairs
Committee

Audit

Export Control Committee
Executive Officers

Sales Divisions/Administrative Offices

14

The chart of the timely disclosure system of the Company is as below.
Party which provides information

Subsidiaries
Sales
Divisions/
Administrative

ReportOfficesAffiliate Management Section, Accounting
Dept. of Financial Management OfficeInternational Affiliate Management Office

Check function

Report(Issues presented in a request for
approval and to the Shinsa Kaigi and theKeiei Kaigi)

Financial Management Office
Legal Dept. of Risk Management Office
General Affairs Office

Party which collects information
Financial Management Office and General Affairs Office (Judgment)

ReportPlanning of disclosure statement
Person responsible for information disclosure

Proposal

Submission of original
proposal for disclosure
President

Approval for disclosure

Submission

Board of Directors

Keiei Kaigi

Procedures for disclosure
Financial Management OfficeInformation Disclosure

15