Disclosure Policy

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1. Basic Stance

At Nikon, we aim to have our company better understood by the capital markets and by our shareholders and other stakeholders. To that end, we implement an approach that is rooted in our corporate philosophy--Trustworthiness and Creativity. That approach entails appropriate information disclosure that is fair, accurate and compliant with laws and regulations. It also involves an active and constructive dialog that can be easily understood. By doing so, we advocate for an appropriate market valuation that reflects our company's intrinsic enterprise value.

2. Information Subject to Disclosure

The information subject to our company's disclosure policy includes: all material external disclosures by the Nikon Group; all reports and documents required to be prepared and submitted under the Financial Instruments and Exchange Act and the Companies Act; material company information required to be disclosed by the Tokyo Stock Exchange; important facts deemed better to be disclosed promptly in light of shareholder interests or environmental and social factors; and regular publications and the like disseminated by the Nikon Group.

3. Information Disclosure Standards

Nikon promptly discloses the above-described information in compliance with the Companies Act, the Financial Instruments and Exchange Act, and other laws and regulations, as well as stipulations related to the timely disclosure of company information set forth in the Tokyo Stock Exchange's Marketable Securities Listing Rules (Timely Disclosure Rules). In the event of decisions, events or information related to financial results that would have an important impact on investment decisions, Nikon will promptly disclose that information in accordance with the standards of the Timely Disclosure Rules. Additionally, Nikon will actively disclose information deemed to be beneficial to investors’ investment decisions, even if that information falls outside of the scope of the Timely Disclosure Rules. Note that Nikon will NOT disclose: personal information, customer information or information that would infringe the rights of parties concerned; pending investments or litigation matters; business information that, if disclosed, would be significantly detrimental to the company’s business or competitiveness; or matters that, if disclosed prematurely, would likely damage shareholder interests.

4. Information Disclosure Methods

Information subject to the Timely Disclosure Rules will be disclosed on the Tokyo Stock Exchange's timely disclosure information dissemination system (TDnet). Then, the same information will be provided to media institutions and promptly uploaded to our website. Information deemed to help our stakeholders understand Nikon better will be broadly disclosed in places including our website, even if that information falls outside of the scope of the Timely Disclosure Rules. TDnet and our website are important sources of information but may not comprehensively include all of the information that Nikon has publicly disclosed. Furthermore, in some cases the information may be expressed differently than information disclosed using other methods. Nikon will take the initiative to voluntarily enhance information disclosure, leveraging non-financial information such as medium-term management strategies, environmental and social activities, dialogs and presentations, as well as answers to day-to-day inquiries.

5. Internal Organization for Information Disclosure

Nikon builds and maintains an organization to appropriately manage our disclosure policy and execute timely and appropriate information disclosure based on the Timely Disclosure Rules. Our organization responsible for information disclosure maintains close ties with internal business units and gathers and analyzes information appropriately. It also clearly defines the process from the occurrence to the disclosure of information, so that our company may exercise appropriate judgment on information disclosure. In principle, our IR department engages in communication with shareholders and investors. However, our Chief Financial Officer (CFO), who oversees information disclosure, and our Investor Relations Officer may respond to requests for communication as necessary. We also aim to enhance opportunities to disclose information through presentations, investor meetings, and uploads to our website.

6. Information Management

Information related to the Nikon Group’s financial results (financial results as well as performance forecasts) is gathered on a regular basis, absorbed and managed, and disseminated to other internal departments as appropriate by our Finance and Accounting and IR organizations. To ensure appropriate management of important information, information management rules have been set forth based on the Nikon Group's basic policy on information security. We endeavor to thoroughly communicate to all employees in the Nikon Group to strictly manage confidential information and ensure that information is not leaked to third parties before such information is disclosed in a fair and appropriate manner.

7. Preventing Insider Trading

We set forth insider trading prevention rules within the Nikon Group and provide education so that all group employees abide by those rules. By doing so, we aim to manage important information appropriately, prevent insider trading and conduct fair information disclosure. At the point in time when company information subject to the Timely Disclosure Rules is disclosed by way of TDnet, the public announcement measure under insider trading rules is complete. Company information subject to the Timely Disclosure Rules and important company information deemed to impact investment decisions is promptly uploaded to TDnet.

8. Silent Periods

Nikon establishes silent periods, which run from the day following the closing of a quarter until the day that quarter's financial results are announced. The purpose of a silent period is to prevent leaking of financial information while the financial results are being prepared for announcement and to secure fairness in disclosure. During silent periods, in principle we refrain from IR activities and do not answer or comment on questions related to the financial results. However, if something happens that causes our projections to stray significantly from previously announced business performance forecasts, that information will be disclosed as appropriate in accordance with the Timely Disclosure Rules, even if the timing of such disclosure falls within a silent period. The same applies to inquiries related to information about past disclosures.

9. Scope of Disclosure during Dialogs and Responding to Third-party Valuations of Nikon

Nikon secures fairness in access to information and transparency in relationships by limiting its comments during individual meetings with institutional investors, analysts and the like to facts already in the public domain and information on the general business environment that, in and of itself, would not influence investment decisions. We do not support comments or performance forecasts about our company that are issued by third parties or rooted in market rumors. However, if those discussions are clearly erroneous and deemed to have a significant impact, we put out information aimed at correcting the mistake and providing an accurate account.

10. About Forecasts

Of the information that we disclose, including performance forecasts, strategies, directional aims and objectives, that which is not historical fact comprise forecast statements. These forecasts are based on available information and management judgments backed by plans, expectations and judgments derived from certain assumptions deemed rational at the time of disclosure. Actual business performance may differ significantly depending on a variety of risks and uncertainties, including changes to the business environment and economic situation.

11. Shareholders’ Understanding

We leverage day-to-day inquiries and voting results and opinions expressed at general shareholder meetings to earnestly strive to deepen our understanding of shareholder concerns and the disclosures and explanations expected of us. Furthermore, we continually analyze the status of holdings in our company's shares, identify priority challenges based on changes in shareholder composition, and reflect these learnings into IR activities aimed at building a shareholder portfolio that will contribute to the stability and enhancement of our enterprise value. Moreover, we will view those investors who have provided numerous strategic suggestions in the past and with whom we believe it would be preferable to continue a dialog as potential shareholders, regardless of their ownership of our shares. The opinions expressed to us through dialogs with shareholders are utilized internally as feedback on a regular basis and leveraged to advance our company's corporate governance and management strategy.

12. Other

When searching our website for information, please refer not only to this disclosure policy but also to separately posted disclaimers.