Disclosure Policy

(1) Criteria for disclosure

QD Laser discloses information quickly with a commitment to ensuring transparency, impartiality, and continuity, in accordance with laws and regulations such as the Financial Instruments and Exchange Act and the “Timely Disclosure of Corporate Information, etc.” section of the Securities Listing Regulations established by the Tokyo Stock Exchange (hereinafter “Timely Disclosure Rules”). We also actively and impartially disclose information deemed to be important or beneficial for shareholders and investors to understand our company, even when not specified by laws and regulations or the Timely Disclosure Rules. QD Laser does not disclose personal information, customer information, or information that would violate the rights of stakeholders.

(2) Method of disclosure

QD Laser discloses information specified in the Timely Disclosure Rules through the Timely Disclosure network (TDnet), which is provided by the Tokyo Stock Exchange, in accordance with the said rules. The information is also published on our website soon after it is disclosed on the network. Information for which the Timely Disclosure Rules does not apply but has been deemed important or beneficial is also made widely available to the public through our website and other means.

(3) Prevention of insider trading

To prevent insider trading, QD Laser has formulated information management rules and insider trading management rules. We make every effort to ensure that all officers and employees are made aware of and understand these rules through measures such as holding annual workshops on insider trading rules and distributing handbooks. QD Laser also warns officers and employees about insider trading as needed through internal notices.

(4) Performance forecasts and forward-looking statements

Information disclosed by QD Laser such as performance forecasts, future outlooks, strategies, and targets not related to past or current facts are forward-looking statements. These statements are premised on information the company has at the time, and on plans, expectations, and decisions based on certain assumptions deemed to be rational. Therefore, actual performance and other results may differ from disclosed forecasts of performance and results due to changes in uncertainty factors such as economic conditions.

(5) Quiet period

QD Laser has established a quiet period from the day after the last day of the fiscal quarter to the day financial results are announced in order to prevent financial results information (including quarterly financial results) from being leaked and to ensure the impartiality of disclosures. During this period, we refrain from responding to questions and commenting on financial results and performance outlooks. However, when a dramatic change in our performance forecast is expected to occur during this period, we will make an announcement as needed in accordance with the Timely Disclosure Rules.

(6) Internal system

QD Laser makes every effort to enhance and improve our internal system so that information is disclosed properly in compliance with laws, regulations, and the Timely Disclosure Rules in accordance with this disclosure policy.