Nippon Paint : Updated Disclosure Policy

1. The Company will, on the principles of transparency, fairness, and consistency, strive to provide information promptly to all stakeholders including shareholders and investors so that they can understand the 'Purpose' and 'Business Philosophy', management strategies, business activities, etc., of the Group, through which we aim to gain a fair evaluation of the corporate value of the Company and trust from them.
2. The Company will, in accordance with the timely disclosure rules prescribed by financial instruments exchanges, disclose information on a timely basis through TDnet and also disclose the same information promptly in the website of the Company. The Company will also actively disclose any information that is judged by the Company to be useful for all stakeholders for them to better understand the Group.
3. The Company will designate a certain period around one month preceding the announcements of earnings results as a 'quiet period,' during which it will refrain from replying to any questions or comments on earnings results in order to prevent the leakage of earnings result information, and to ensure fairness. However, in the event of an expectation arising that significantly differs to the performance forecast during the quiet period, information shall be disclosed at the appropriate time and in the appropriate manner, in accordance with the timely disclosure rules, etc.
4. The Company will strive to disclose information also in English from the perspective of fairness.

*Note

• Any posting on the website of the Company that is not a historical fact is a statement of forecasts made by the Company based on information that was available when it was published. These forward-looking statements include known and unknown risks, uncertainties and other factors. Actual results may prove to be different from these forecasts.
• Although the Company strives to ensure the accuracy of information published on its website with the greatest possible care, the Company shall not be held liable for any damage arising from an error in the published information or a failure during the browsing and downloading of information.
• The information published on the website of the Company is intended for the purpose of providing information and not for the purpose of investment solicitation. The readers of the website of the Company are asked to make investment decisions based on their own judgment and at their own responsibility.

Basic Policy on Dialogue with Shareholders

1. The Company, through the thorough performance of fair information disclosures (fair disclosures) and ongoing dialog with domestic and overseas shareholders, shall construct a relationship of trust with shareholders, and in addition, shall contribute to Maximization of Shareholder Value through the reduction of information asymmetry and the suppressing of capital costs.
   
2. The Company, for constructive dialog with shareholders, shall endeavor to ascertain the shareholder structure. In having such dialogue, the Company will pay close attention to any possibility of a leakage of insider information.
3. The Company shall designate the Representative Executive Officer & Co- President, General Manager of the Investor Relations Department, and the General Manager of the General Affairs Department as the contact points for dialog with shareholders. The officer shall provide feedback on the opinions of shareholders expressed in the course of the dialogue regularly to the Board of Directors and useful comments will be reflected in the management.

Information Disclosures and Dialogue Subject to the IR Policy

1.Statutory Disclosures

（1）Disclosures in Accordance with the Financial Instruments and Exchange Act Securities registration statement, annual securities reports, quarterly reports, extraordinary reports, etc.

（2）Disclosures in Accordance with the Companies Act

Notice of General Meeting of Shareholders, business reports, financial statements, consolidated financial statements, etc.

2.Disclosures Required by the Financial Instruments Exchange

（1）Timely Disclosure

Disclosures of information about corporate decisions and events occurred and financial information, etc. required by the Tokyo Stock Exchange

（2）Corporate Governance

Response to the Corporate Governance Code and Corporate Governance Report required by the Tokyo Stock Exchange

3. Other Information Disclosures

（1）Presentation materials/videos

（2）Integrated reports

（3）Shareholder newsletters

（4）Investor Relations (IR website)

（5）Daily dialogue with analysts and institutional investors, etc.

Timely Disclosure Structure

1. We are working to enhance and strengthen corporate governance to realize fair and highly transparent management. In particular, the Company regards speedy and accurate disclosure to investors in compliance with the provisions of the Financial Instruments and Exchange Act and other applicable laws and regulations and timely disclosure rules prescribed by financial instruments exchanges as an important management role and has adopted the following internal system.
2. Information on financial results will be reported to the Board of Directors after these results are finalized by the Finance & Accounting Department and audited by the accounting auditor, and they are then disclosed as a summary of accounts on the day of approval. Regarding revisions of financial forecasts, the Representative Executive Officer and Co-President receive regular reports on the earnings outlook from the Finance & Accounting Department, monitor any changes in the expected financial performance of the Group due to changes in the business environment and deliberate on measures to respond to such changes. Based on the results, the Board of Directors reports and deliberates whether the announced earnings forecast should be revised.
3. Information on the decision is promptly disclosed in accordance with timely disclosure rules after the decision is made by an appropriate decision making authority such as the Board of Directors.
4. Regarding information on the occurrence of such, the officer in charge of the head office collects and promptly discloses all information in accordance with timely disclosure rules, and also voluntarily discloses certain other important facts.
5. Information on subsidiaries is specified in the internal rules as a matter that the officer in charge should report to the Company, and since matters of high importance require approval by the Board of Directors of the Company, they are disclosed in accordance with timely disclosure rules through deliberation.
6. The general affairs department manager has been appointed as the insider trading information manager. Handling of information subject to insider trading regulations is stipulated in the Insider Trading Prevention Rules, and the insider trading information manager manages the operation thereof (See the chart below.)
7. After registering with TDnet, the Investor Relations Department and the Public Relations Department will handle any inquiries regarding disclosure information. The Company strives to provide opportunities for investors, etc., to have fair and easy access to information. For example, the Company publishes the same information in the website of the Company promptly after it is disclosed to the financial instruments exchange.

Structure to Prevent Insider Trading

The Company, through the partnership of the Representative Executive Officer & Co-President, management team, and the general managers of the departments set forth below, shall engage in investor relations activities, statutory disclosures, timely disclosures, disclosure of important decisions, and shareholder relation activities.

• Investor Relations Department
• Public Relations Department
• Finance & Accounting Department
• General Affairs Department
• Other Related Departments

Target

Initiatives

Activities in FY2020

Target

Institutional investors
(domestic/overseas)

Initiatives

Held direct dialog through various investor briefings and individual meetings with investors, etc.

Activities in FY2020

• Held conference call on each quarterly results announcement date
• Management policy presentation meeting
• Held individual meetings for domestic and overseas investors
• Participated in conferences held domestically and overseas by securities companies

Target

Individual shareholders/
investors

Initiatives

Held various briefings to explain management strategies and earnings trends, etc.

Activities in FY2019

• Investor presentation meeting (online)