MODEC : Plan to comply with the criteria to maintain listing under the new Tokyo Stock Exchange (TSE) market categories

This document has been translated from the Japanese original for reference purposes only. In the event of any discrepancy between the translated version and the Japanese original, the original version shall prevail. The Company assumes no responsibility for this translation or for any direct, indirect or any other form of damage arising from the translation.

November 18, 2021

MODEC, INC.

Takeshi Kanamori, President & CEO

Code	TSE 6269
Contact	Budget & Planning Group
TEL	[phone]

Plan to comply with the criteria to maintain listing

under the new Tokyo Stock Exchange (TSE) market categories

MODEC, INC. submitted an application today to select the Prime Market segment when TSE revises its market segments (scheduled in April 2022).

As we did not fulfill the requirement to become listed on the Prime Market as of the reference date (June 30 2021), we have prepared an action plan to achieve it, as stated below.

• The status of compliance with the criteria and the planning period

Our status of compliance with the criteria to become listed on the Prime Market as of the reference date is as follows. As of that date, we did not fulfill the requirement of floating stock ratio. Thus we will take various measures to improve it to meet the required level by the end of December 2023.

			The number of		Total market value		Floating stock			Average daily
			floating stock		of floating stock		ratio			trading value
			(unit)		(billion JPY)		(%)			(billion JPY)
	Our Status		191,816 units		JPY41.8bil	34.0%			JPY0.32bil
	as of the reference date
	Criteria to become listed		20,000 units		JPY10.0bil	35.0%			JPY0.02bil
	on the Prime Market
	Items to be included						Yes
	in the plan

(Note) Our status as of the reference date is calculated based on the information of distribution of share certificates, etc.

• Basic plan, issues and details of actions to comply with the criteria

(Basic plan)

We intend to improve the liquidity of the stock in order to promote our constructive dialogue with investors.

(Issue)

Floating stock ratio is low because 64.96% of stocks are owned by major shareholders on the back of the history of company's incorporation and business collaboration agreement for FPSO business promotion.

(Action plan)

We will improve our enterprise value through our Mid-term Business Plan which focuses on (1) FPSO business promotion, (2) Incubation of next business centering on renewable energy, (3) Digitalization strategy. In that process, we will make effort to improve our floating stock ratio by requesting business corporations and financial institutions to sell the stock identified as "Fixed stock" based on criteria for Prime Market.

MODEC Group Mid-term Business Plan 2021-2023https://www.modec.com/ir/library/presentation/assets/pdf/midterm_strategy_2021-2023_en.pdf