Disclosure Policy

Basic Policy for Disclosure

The basic policy for IR of SpiderPlus & Co. (the “Company”) is to make accurate, fair and timely disclosures of information to all of our stakeholders including shareholders and investors, pursuant to the Financial Instruments and Exchange Act and relevant laws, regulations and rules such as the Timely Disclosure Rules of the Tokyo Stock Exchange. In addition, the policy is to endeavor to proactively make disclosures of information that we believe will be useful for understanding the Company.

Method of Information Disclosure

Disclosures of information corresponding to the Timely Disclosure Rules are made through the Timely Disclosure network (TDnet) provided by the Tokyo Stock Exchange, disclosures of securities reports, quarterly reports, etc. under the Financial Instruments and Exchange Act, etc. are made through the Electronic Disclosure for Investors’ NETwork (EDINET) by the Financial Services Agency, and the information that has been publicized will also be promptly disclosed on the Company’s IR site. In addition, our policy is to promptly and fairly disclose by appropriate methods other information that does not correspond to the Timely Disclosure Rules but are believed to be useful for all of our stakeholders based on the intent of the fair disclosure rules set forth in the Timely Disclosure Rules and the Financial Instruments and Exchange Act.

Quiet Period

From the perspective of preventing the leakage of financial information and securing the fairness of information disclosure, the “closing date until the announcement date of financial results” of each quarter has been set forth as the IR Quiet Period. During this period, we will refrain from responding to questions and making comments concerning the financial results and earnings estimates. However, even if it is during such quiet period, if a material fact occurs that is determined to have a significant impact on the investment decisions of the investors or disclosure is required under the various laws and regulations or Timely Disclosure Rules, timely and proper disclosure of information will be made.

Prevention of Insider Trading and Fair Disclosure of Information

In order to prevent insider trading, the Company has set forth relevant internal rules and is promoting the thorough awareness, understanding and education of all of our officers and employees. In addition, the Company aims to prevent insider trading by properly managing information concerning material facts that affect investment decisions and through prompt disclosures of information in accordance with the various laws and regulations and the Timely Disclosure Rules.

Development of Internal Systems

The Company endeavors the develop and enhance our internal systems, in accordance with this IR Policy, to carry out the proper disclosure of information pursuant to the Financial Instruments and Exchange Act and other laws and regulations, and relevant laws, regulations and rules such as the Timely Disclosure Rules set out by the Tokyo Stock Exchange.