Disclosure Policy

Santen stipulates that our fundamental disclosure policy is to provide our shareholders and investors with company information in an accurate, fair, timely and appropriate manner. In this context, we disclose our corporate information in accordance with applicable laws and regulations including Japan’s Financial Instruments and Exchange Act, the Timely Disclosure Rules set by the Tokyo Stock Exchange where our stocks are listed as well as guidelines on disclosure of information established by Santen independently.

Santen will disclose, in a timely and appropriate manner, any new information related to decisions, events, financial accounting or other matters that may significantly affect investments in securities; any inquiries lodged by the Tokyo Stock Exchange; and any important changes or repeals made to corporate information already released. Although information to be disclosed may concern pharmaceuticals or newly developed products, such information will not be intended for any promotion or medical advice.

Information disclosed is subject to addition, change or deletion without notice.

Pursuant to the applicable laws and regulations and Timely Disclosure Rules, Santen discloses information through the Electronic Disclosure for Investors’ NETwork (EDINET), a system provided by the Financial Services Agency or through the Timely Disclosure network (TDnet) provided by the Tokyo Stock Exchanges, amongst other methods.

Information released through EDINET, TDnet and other means will also be posted on our corporate website for the sake of timeliness and fairness.

Furthermore, under our policy of timely disclosure Santen will endeavor to release information concerning matters beyond the scope of the applicable laws and regulations and the Timely Disclosure Rules in an appropriate, accurate, fair and expeditious manner.

Santen prevents insider trading by stipulating in its internal rules clear guidelines for the proper control of internal information and the trading of shares; by ensuring that its officers and employees thoroughly understand and comply with the regulations concerning insider trading.

Santen may provide financial forecasts through means beyond those required by the Tokyo Stock Exchange.
Information on business plans, forecasts and strategies may be included in press releases, company-issued documentation, website contents, meetings on financial results and analyst meetings.
However, such information would have been chosen from data available at the time when the Santen management team made practical determinations for disclosure, and therefore may entail arbitrary degrees of risk and uncertainty.
As such, actual results may differ greatly from previous forecasts due to various factors. Please refer to the section on business risk for more details.

Santen's basic policy is to refrain from commenting about market rumors and speculation. However, we will take appropriate and timely action if we conclude that such rumors and speculation will severely affect our ability to operate in the market or if stock exchanges or other agencies ask us to provide explanations.

To ensure fairness and to prevent leaks of important corporate information such as that pertaining to financial performance, Santen has designated a quiet period that starts on the day immediately following the closing day of each quarter and ends on the day of the release of the financial results of that quarter. Santen will refrain from providing comments or answering inquiries about our financial performance during this period. However, we will release information about any events within the scope of our timely disclosure policy that may arise during the quiet period. The terms of this quiet period do not apply to inquiries regarding information already released.

Santen has established Investor Relations Group (“IR”) and the division for Corporate Communications (collectively, “Departments Handling Information”) as the departments involved in handling disclosure of internal and external information. The Departments Handling Information play the primary role in timely disclosure, by handling in an integrated manner the information from the individual divisions including the subsidiaries and headquarters. Departments Handling Information endeavor to maintain the system to be capable of collecting information on matters required to be disclosed, prevent disclosures mistakenly made without first obtaining internal approval, as well as disclose accurately the content of any critical incident that may have a material effect on Santen.
As to information concerning financial closing based on Japan’s Financial Instruments and Exchange Act, Departments Handling Information and relevant departments ensure the validity and accuracy of information, followed by the deliberation and approval by the Board of Directors before disclosure.