Accordia Golf : NOTICE REGARDING SETTING OF RECORD DATE FOR CONVOCATION OF EXTRAORDINARY MEETING OF SHAREHOLDERS

[Translation]

December 26, 2016

To whom it may concern

Company Name Accordia Golf Co., Ltd.

Name of Representative Yuko Tashiro, President and

Representative Director

(Stock Code: 2131, First Section of the Tokyo Stock Exchange)

Inquiries Fumihiko Niwa, Director and Corporate Officer

Telephone: [phone] (main)

NOTICE REGARDING SETTING OF RECORD DATE FOR CONVOCATION OF EXTRAORDINARY MEETING OF SHAREHOLDERS

Accordia Golf Co., Ltd. (the "Company") hereby announces that it has resolved today at its Board of Directors meeting as follows on the setting of the record date that would be required in the case that the Company convenes an extraordinary meeting of shareholders (the "Extraordinary Shareholders' Meeting") in late February 2017.

1. Record Date for the Extraordinary Shareholders' Meeting

   In preparation for the case in which it holds the Extraordinary Shareholders' Meeting, the Company resolved to set January 26, 2017 (Thursday) as the record date for the Extraordinary Shareholders' Meeting and determined that the shareholders described or recorded in the last shareholder registry as of January 26, 2017 will be entitled to vote at the Extraordinary Shareholders' Meeting.

2. Date of Public Notice: January 11, 2017 (Wednesday)

3. Record Date: January 26, 2017 (Thursday) (the "Record Date")

4. Method of Public Notice: Electronic public notice

5. (to be posted on the Company's website: http://www.accordiagolf.co.jp/info/ea/)

6. Schedule and Agenda for the Extraordinary Shareholders' Meeting

7. As announced in the press release titled "Notice of Commencement of Tender Offer for Share Certificates of the Company by K.K. MBKP Resort and Recommendation to Tender Shares" dated November 29, 2016, if the tender offer (the "Tender Offer") for the shares of common stock of the Company (the "Company's Common Stock") announced by K.K. MBKP Resort (the "Tender Offeror") on November 29, 2016 is completed, and (i) upon completion of the Tender Offer, if the total number of voting rights of the Company owned by the Tender Offeror becomes at least 90% of the voting rights of all shareholders of the Company and the Tender Offeror becomes a special controlling shareholder as set forth in Article 179, Paragraph 1 of the Companies Act (Act No. 86 of 2005, as amended; the "Companies Act"), the Tender Offeror plans to request all of the Company's common shareholders (excluding the Company and the Tender Offeror) to sell all of the Company's Common Stock they own pursuant to the provisions of Part II, Chapter II, Section 4-2 of the Companies Act (the "Demand for Shares Cash-Out") as the procedures so that the Tender Offeror will acquire all of the Company's Common Stock (the "Procedures for Making Accordia Golf co., Ltd. a Wholly- owned Subsidiary"), and otherwise, (ii) if after the completion of the Tender Offer the total number of the Company's voting rights held by the Tender Offeror is less than 90%, the Tender Offeror plans to request (the "Request") the Company to hold an extraordinary shareholders meeting that includes each of the following as proposals submitted for deliberation: (x) a proposal to conduct a consolidation of the Company's Common Stock (the "Stock Consolidation") and (y) a proposal to amend the articles of incorporation (subject to the Stock Consolidation becoming effective) for the purpose of abolishing the provision regarding the number

   of shares constituting one unit of stock. If the Tender Offeror makes the Request, the Company will submit the proposals to conduct the Stock Consolidation and to partially amend the articles of incorporation (subject to the Stock Consolidation becoming effective) for the purpose of abolishing the provision regarding the number of shares constituting one unit of stock.

   Because the Request will be made in the case of (ii) above and this would require the holding of the Extraordinary Shareholders' Meeting, the Company has determined, by way of preparation, to set in advance the record date that would be required for convocation of the Extraordinary Shareholders' Meeting. If the Extraordinary Shareholders' Meeting is to be held, the Company will announce the date, place and agenda of the Extraordinary Shareholders' Meeting and other matters once it has decided them.

   If, on the other hand, the Tender Offeror acquires at least 90% of the voting rights of all shareholders of the Company by way of the Tender Offer, and the Tender Offeror makes the Demand for Shares Cash-Out as the Acquisition Procedure, the Company will not hold the Extraordinary Shareholders' Meeting or use the Record Date.

   End

   For inquiries, please contact: Accordia Golf Co., Ltd.

   Corporate Communication IR (K. Nose) TEL: [phone] (audio guidance)

   E-mail: [e-mail]

   (Monday-Friday, 9:00 a.m. to 5:00 p.m. Japan Standard Time)