1. Information Disclosure Policy

SMM discloses information in a fair, timely and appropriate manner to shareholders, investors and other stakeholders, and complies with the Companies Act, Financial Instruments and Exchange Act, and Securities Listing Regulations. SMM also proactively discloses information for which disclosure is not mandatory under the Securities Listing Regulations if it is considered useful for broadening understanding of SMM.
Determination of whether information should be disclosed or not is the responsibility of a predesignated person (General Manager of the Public Relations & Investor Relations Department).

2. Prohibition of Selective Disclosure

SMM does not disclose important unpublished information selectively to shareholders, institutional investors, security analysts, individual investors, or other such parties except in cases where the secrecy of information is guaranteed by a non-disclosure agreement. If SMM becomes aware that important unpublished information has been selectively disclosed, we swiftly disclose this information in principle.

3. How Information is Disclosed

SMM releases information for which disclosure is mandatory under the stipulations of the Securities Listing Regulations through the Tokyo Stock Exchange’s TDnet (Timely Disclosure Network) and press releases in accordance with these regulations, and then promptly posts the same information to the SMM website. We also try to ensure that shareholders and investors receive information for which disclosure is not mandatory in a fair, timely, and appropriate manner under the principle of timely disclosure.

4. Quiet Period

In order to prevent the leak of financial results information and ensure fairness, SMM has defined about two weeks prior to the announcement of annual and quarterly financial results as a “Quiet Period,” in which we shall refrain from commenting on or answering questions regarding financial results. However, if, during a Quiet Period, a large discrepancy between the announced expected results and the actual results is forecast, SMM shall swiftly disclose information in accordance with the stipulations of the Securities Listing Regulations.

5. Future Outlook

Plans, forecasts, business targets and other matters that are not historical facts and are published on SMM’s website are based on SMM’s judgment and predictions using currently obtainable information. Please be aware that actual business performance may differ greatly from forecasts due to a variety of factors. Factors that impact business performance include but are not limited to market forces, non-ferrous metal and precious metal prices, supply and demand trends for functional and other materials, market conditions, and exchange rates.

6. Investment Criteria

The information published on the SMM website is for the purpose of broadening knowledge of SMM and is not for the solicitation of investments. Please make your own judgments regarding investments.