Disclosure Policy

1. Basic Policy

In order to ensure transparency of corporate management, MEDLEY INC. (hereinafter “the Company”) will strive to disclose corporate information in timely and appropriate manner. With regard to disclosure of such information, the Company will proactively endeavour to expand the scope of disclosure beyond information required by the Financial Instruments and Exchange Act and other laws as well as the Timely Disclosure Rules set forth by the Tokyo Stock Exchange and regulations to information deemed beneficial to facilitate understanding of the Company for all stakeholders.

2. Method of Information Disclosure

The disclosure of information applicable to the Timely Disclosure Rules is disclosed via the timely disclosure information communications system (TDnet) provided by the Tokyo Stock Exchange in accordance with the set rules. Furthermore, following such disclosure, the Company shall immediately publish the same information to this IR website. In addition, in the spirit of the timely disclosure to the shareholders and stakeholders, we will endeavour to disclose the Information which we deem important as proactive and fair as possible to this website, even if such disclosure is not mandated by the set rules.

3. Prevention of insider trading

The Company sets forth internal rules and regulations to prevent any potential insider trading, and strives to educate our directors and employees about such rules and regulations in proper manner. In addition, the Company puts forth substantial efforts to prevents insider trading by appropriately controlling material undisclosed information that could affect investors’ decisions, and appropriately disclosing applicable information in accordance with all relevant laws and Timely Disclosure Rules.

4. Quiet Period

The Company sets forth the “quiet period” from the day following the end of each quarterly and annual accounting period until the announcement of financial results (quarterly, or annual) for the purpose of ensuring fairness and preventing the leakage of earnings-related information. During this period, the Company will refrain from replying to queries concerning operating results or commenting on such matters. However, exceptions may be made when material events affecting investors’ decision arise, or required by laws or Timely Disclosure Rules.

5. Internal structures

In accordance with this Disclosure Policy, the Company strives to improve and strengthen our internal management system in order to provide appropriate information disclosure in accordance with the laws and Timely Disclosure Rules.

6. Others

In obtaining the Company information from this website, please refer to Disclaimer, other rules and policies posted on this website along with this Disclosure Policy.