The second chapter. Insider information management
Article 4【Insider information management】
① Executives and employees shall strictly control the internal information of the company that they have learned in their work, and shall not disclose internal information to the inside or outside of the company, except when necessary for business purposes.
② The representative director or public announcement officer shall take necessary measures for internal information management, such as setting specific standards for custody, transmission and destruction of internal information and related documents.
Article 5【Public announcement Officer】
① The CEO shall declare the officer in charge of public announcement and immediately report it to the Exchange. The same shall apply when the person responsible for public announcement is changed.
② The officer responsible for public announcement shall oversee the tasks related to the establishment and operation of the internal information management system and perform the following duties.
1. Enforcement of public notice
2. Checking and evaluating the operation of internal information management system
3. Review of internal information and determination of public announcement
4. Measures necessary for the operation of the internal information management system, such as training for officers and employees
5. Directing and supervising internal information management or department or officer / employee in charge of public announcement
③ The officer in charge of public announcement shall have the following rights in carrying out his duties.
1. The right to request and view the submission of documents and records related to internal information
2. The authority to listen to the necessary comments from the officers and employees of the department responsible for the creation of internal information and the department responsible for accounting or auditing
④ The public announcement officer may consult with the officer in charge of carrying out the duties, and may seek expert assistance at the expense of the company.
⑤ The public announcement officer shall periodically report to the representative director (or the board of directors) the operational status of the internal information management system.
Article 6【Public announcement officer】
① The representative director or the public announcement officer shall determine the person responsible for public announcement and notify the Exchange immediately without delay. It is also the same when the public announcement officer is changed.
② The public announcement officer shall be under the direction of the leading officer of public announcement in relation to internal information management and shall perform the following duties.
1. Collecting and reviewing internal information and reporting to the person in charge of public announcement
2. Duties necessary for execution of public announcement
3. Identification of matters necessary for the management of internal information, such as changes in laws and regulations related to public announcement , and reporting of public announcement officers
4. Other matters deemed necessary by the CEO or the public announcement officer
Article 7【Centralization of insider information】
①The officers and the heads of the respective departments shall provide information to the public announcement officer in cases where any of the following falls
1. Internal information occurs or is expected to occur
2. If there is any reason to cancel or change the already announced internal information, or if it is expected to happen
3. If there is a request from the public announcement officer
② The public announcement officer and the representative director shall establish an information delivery system within the company for timely provision of internal information pursuant to Paragraph 1. If necessary, the public announcement officer may be assisted in the process of approval of the duties related to the public notice requirements.
Article 7-2【Management of the largest shareholder-related information】
The information sharing system should be established by the public announcement officer, so that the largest shareholder can fully explain the relevant facts and receive relevant information in a timely manner, to facilitate public notice of public announcement obligations and public announcement requirements related to the largest shareholder,
Article 7-3【Centralization of internal information of subsidiary company 】
① If the internal information related to the public announcement requirements arises or is expected to occur in the subsidiary company, the Company shall promptly notify the subsidiary company of the information to the company's public notice officer or leading officer of public announcement.
② In order to efficiently manage the internal information related to the public announcement obligations pursuant to Paragraph 1, the Company shall have a person who manages public announcement related information in its subsidiary company. If designated or changed, the Company shall notify the public announcement officer or the leading officer of public announcement immediately do.
③ The Company may require subsidiary company to submit relevant materials to the extent necessary for their public announcement duties.
Article 8【Providing internal information to outside the company】
① If an officer or employee must inevitably provide internal information to a counter party, an external auditor or agent of the company, a person who has concluded an advisory contract with the company, legal advice, management consultation, etc. for business reasons, it should be reported to public announcement officer.
②In the case of Paragraph 1, the public announcement officer shall take necessary measures, such as concluding a contract on the confidentiality of relevant internal information.
③ If an obligation for fair disclosure occurs in providing internal information pursuant to Paragraph 1, it shall be disclosed without delay (Exceptions to the application of Article 15 of the Public announcement Regulations)