The Investment Corporation aims to make prompt, accurate and fair information disclosures consistently from the viewpoint of shareholders while also thoroughly recognizing that timely and appropriate information disclosures to investors are the basis of a healthy market for financial products. Based on this perspective, the Heiwa Real Estate Asset Management, Co., Ltd. (hereafter referred to as “Asset Management Company”), which is entrusted with the management of the assets by the Investment Corporation, has adopted the system below in order to make timely disclosures of information.
1. Basic Information Disclosure Policy
The Asset Management Company will accurately, fairly and timely disclose to investors information relating to the Investment Corporation and the Asset Management Company in accordance with the system for the disclosure of corporate affairs, etc., under the Financial Instruments and Exchange Act, the “Securities Listing Regulations” prescribed by the Tokyo Stock Exchange Group, Inc. and the “Regulations Concerning Representation of Advertising, etc. and Offer of Premiums” prescribed by The Investment Trusts Association, Japan. In addition, even if the information does not fall under the “Securities Listing Regulations,” timely disclosures shall be made when the information is deemed useful to investors.
When engaging in IR activities and other communication about the Investment Corporation with trading participants such as financial instruments business operators and investors (as defined in the Financial Instruments and Exchange Act), the Asset Management Company will heed the fair disclosure rules provided for in the Financial Instruments and Exchange Act, and disclose information in a prompt, accurate and fair manner in accordance with the rules as required.
2. Implementation of Timely Disclosure
The implementation of timely disclosures shall be through posting on the Tokyo Stock Exchange Group, Inc.’s TD-net (Timely Disclosure Network), distribution of documents to the Tokyo Stock Exchange Press Club (Kabuto Club), the Ministry of Land, Infrastructure, Transport and Tourism Press Club and the Ministry of Land, Infrastructure, Transport and Tourism Press Club for Construction Publications, disclosure on the Investment Corporation’s website and through other information media. Consideration will be given so that the relevant information is fairly distributed.
3. System Relating to Timely Disclosure
Operations relating to the timely disclosure of information will be under the charge of the Asset Management Company’s Planning & Finance Department and the General Manager of that department will be the person in charge of handling information.
In addition, officers and employees of the Asset Management Company will, with respect to important asset management and management information relating to the Investment Corporation and the Asset Management Company, immediately report to the person in charge of handling information and will undertake the consolidation of information when an organizational decision has been made about the disclosure of the relevant information or when circumstances arise necessitating disclosure.
Furthermore, in an emergency such as a natural disaster, etc., the Asset Management Company has prepared a system to make timely and prompt information disclosures pursuant to the “Business continuity planning” prescribed as an internal regulation of the Asset Management Company.