Established on: May 1, 2018
1. Basic Policy
NTT UD REIT Investment Corporation (“NUD”) shall set a basic policy “Ensuring prompt, accurate and fair information disclosure from the viewpoint of unitholders/investors at all times” with full recognition that timely and appropriate information disclosure to unitholders/investors are the basis of a sound market for financial instruments and shall take the following specific initiatives.
|(1)||NUD shall make efforts to provide appropriate information for making investment decisions at all times by disclosing, to the greatest extent possible, information that is considered useful for unitholders/investors to understand NUD.|
|(2)||NUD shall make efforts to establish a system which enables prompt transmission of accurate and unbiased information to unitholders/investors.|
|(3)||NUD shall disclose information in accordance with the contents and the formats required by the Act on Investment Trusts and Investment Corporations, the Financial Instruments and Exchange Act, the Tokyo Stock Exchange, The Investment Trusts Association, Japan, etc.|
In order to realize the above basic policy, NUD shall share this disclosure policy with NTT Urban Development Asset Management Corporation (“UDAM”), to which NUD entrusts its asset management, and have UDAM carry out operations of information disclosure for NUD in accordance with the content of this policy.
2. Information Disclosure Standards
NUD shall, under a policy of transparency, fairness and continuity, promptly disclose information pursuant to applicable laws and regulations including the Financial Instruments and Exchange Act, the securities listing regulations stipulated by the Tokyo Stock Exchange, etc.
NUD shall make efforts to disclose, to the greatest extent possible, information that is considered useful for unitholders/investors to understand NUD, even if the information is not subject to disclosure based on applicable laws and regulations including the Financial Instruments and Exchange Act, the securities listing regulations stipulated by the Tokyo Stock Exchange, etc. Furthermore, concerning undisclosed material information on the management, operation or assets of NUD which will have a significant impact on investment decisions by unitholders/investors, NUD shall take the utmost care that the transmission of such information does not lack fairness.
3. Information Disclosure Methods
Concerning information on items where the disclosure of which is required by applicable laws and regulations including the Financial Instruments and Exchange Act, the securities listing regulations stipulated by the Tokyo Stock Exchange, etc., NUD shall disclose such information through the Electronic Disclosure for Investors’ NETwork (EDINET) of the Financial Services Agency, the Timely Disclosure network (TDnet) of the Tokyo Stock Exchange, media organizations, NUD’s website, etc.
In addition, NUD shall also widely disclose other information through NUD’s website, etc.
4. Information Disclosure System
UDAM, which carries out the operations of information disclosure for NUD, establishes the following system:
|(1)||The Planning & IR Department, which is responsible for the operations of information disclosure for NUD, shall promptly and accurately collect material information on NUD that exists in UDAM under the command and supervision of the President and CEO and all other departments shall, in principle, provide such material information to the Planning & IR Department each time such information arises in order to achieve such objective.|
|(2)||Upon disclosure of information on NUD, the Planning & IR Department shall seek prior confirmation from the Compliance Officer with regard to the accuracy and fairness of the content and shall disclose the information after obtaining final confirmation from the President and CEO.|
5. Establishment of Silent Period
For the purpose of preventing any leakage of information on financial results and ensuring fairness, NUD shall set the period from the day following each account closing date until the announcement of financial results as a silent period and shall refrain from answering any questions or making comments on financial results during such period.
However, if more than a certain degree of revision to the performance forecast becomes expected during the silent period, NUD shall promptly disclose it in accordance with the securities listing regulations stipulated by the Tokyo Stock Exchange, etc.
In addition, NUD shall respond as usual during the silent period to inquiries on information that has already been disclosed.
6. Future Outlook
Of disclosed information of NUD, statements regarding matters other than facts in the past or present are forward-looking statements and include various risks and uncertainties. Such information is based on assumptions or judgements of NUD and UDAM derived from the information that was available to NUD and UDAM at the time of disclosure and may differ from the actual performance or the management results.