(1) Information disclosure standards

In accordance with various laws and ordinances, such as the Financial Instruments and Exchange Act, and the “timely disclosure of company information, etc. (hereinafter timely disclosure rules)” under securities listing regulations that are stipulated by the Tokyo Stock Exchange (TSE), Timee, Inc. (hereafter Timee or the Company) aims to promptly disclose information based on transparency, fairness and continuity. In addition, even in cases where disclosure is not subject to various laws and ordinances and to the timely disclosure rules, Timee will actively and fairly disclose information deemed important or useful so that shareholders and investors will gain an understanding of the Company. Note that personal information, customer information and information that infringes on the rights of related parties will not be disclosed.

(2) Information disclosure method

Disclosure of information stipulated by timely disclosure rules will be done so via the timely disclosure information transmission system (TDnet), which is provided by the TSE in accordance with the said rules, and will also be promptly posted to the Timee website after being disclosed on the aforementioned system. Even though not subject to the timely disclosure rules, information that is deemed important or useful will be widely disclosed, including being posted to the Company website.

(3) Prevention of insider trading

In an aim to prevent insider trading, Timee has put related in-house regulations into place, and is making them common knowledge among all employees and is promoting their understanding and awareness. In addition, the Company is aiming to prevent insider trading through the proper management of information related to important facts that could impact investor decisions, and by promptly disclosing information in accordance with various laws and ordinances, and timely disclosure rules.

(4) Handling of earnings forecasts and information about future performance

Of the earnings forecasts, outlooks, strategies, and goals disclosed by Timee, matters other than those related to historical and current facts are forward-looking statements. These matters are based on plans, expectations, and judgements predicated on information currently available to the Company and certain assumptions that are deemed to be reasonable. Consequently, there is a possibility that actual earnings results may differ from the disclosed earnings forecasts, etc. owing to fluctuation factors to various uncertainties, including economic circumstances.

(5) Quiet period

From the perspective of preventing the leak of financial information (including quarterly financial information) and securing the fairness of information disclosure, Timee is setting a quiet period from the business day after the final business day of a fiscal period (quarterly financial results) to the date of announcement of the financial results. During this period, we refrain from responding to questions or making comments related to financial results and earnings forecasts. However, in the event that earnings forecasts are expected to significantly fluctuate during the period, we will make timely announcements in accordance with the timely disclosure rules.

(6) Establishment of in-house system

In accordance with this disclosure policy, the Company is working to establish and enhance an in-house system to implement proper information disclosure that is in line with various laws and ordinances and timely disclosure rules.

(7) Other

When viewing Company information on the Timee website, refer not only to this disclosure policy but also view the disclaimer and other notes which are posted separately.