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Management PolicyDisclosure Policy

Information Disclosure Standard and Policy

GungHo Online Entertainment, Inc. (hereinafter referred to as the “Company”) conducts information disclosure in adherence to the Financial Instruments and Exchange Act and the “Regulations for Timely Disclosure of Corporate Information by Issuers of Listed Securities, etc.” (hereinafter referred to as “Timely Disclosure Regulations”) set forth by the Tokyo Securities Exchange Co., Ltd. The Company acts to promptly disclose information whenever news or information is generated that could affect our shareholders’ and/or investors’ decision with regard to investment, such as board decisions, facts or findings, and financial statements, as well as in the event of an inquiry by a securities exchange.
Furthermore, it is our policy to make every possible effort to ensure transparency and fairly disclose other information to the public that is deemed to be of value in assisting our investors to understand the Company, even if the information is not subject to the Timely Disclosure Regulations.

Information Disclosure Methods

Methods Information that must be disclosed in accordance with the Timely Disclosure Regulations is made public, as stipulated therein, through the Timely Disclosure network (TDnet) (∗ 1). Information disclosed over TDnet is also posted promptly on the Company’s website (∗ 2).
The Company also acts to ensure that information not subject to the Timely Disclosure Regulations, but which could affect investment decisions, is disseminated in an appropriate manner as accurately and fairly as possible.
Therefore, all persons interested in verifying the Company’s disclosure information are invited to refer to TDnet, EDINET ( ∗ 3) and the Company’s website, along with other available information.

(∗ 1): TDnet (Timely Disclosure network) is a system for timely transmission of disclosure information built and operated by securities exchanges in Japan, including the Tokyo Securities Exchange.
(URL:http://www2.tse.or.jp/tseHpFront/StockSearch.do?method=&topSearchStr=3765

(∗ 2): There may be a time lag between disclosure on TDnet and posting on the company website, due to PDF file conversion, etc.

(∗ 3): EDINET (Electronic Disclosure for Investors’ NETwork) is the electronic disclosure system for disclosure documents such as securities reports based on the Financial Instruments and Exchange Act, provided as a government service by the Financial Services Agency.

Important Notice concerning Disclosure

The projections, forecasts, business strategies, etc. reported in the disclosure information of the Company, except for items pertaining to current or past facts, are forecasts of future performance. Although the Company uses its best judgment in forecasting future performance taking into account all information available at the time, it is advisable to refrain from relying solely on these forecasts.

Notice concerning the Company’s Website

Although the utmost efforts are exerted to assure completeness of the contents posted on the Company’s website, its accuracy is not completely guaranteed. The Company’s website should be treated as no more than a supplementary source of information mandated to be disclosed in accordance with the Financial Instruments and Exchange Act and the Timely Disclosure Regulations, and the Company recommends viewing this information in conjunction with Securities Reports, Extraordinary Securities Reports, TDnet, etc. which disclose information that conforms to the aforementioned laws and regulations. Neither the Company, nor any of its employees, etc. will be liable or have any responsibility against any kind of loss or damage incurred through the use of information posted on the Company’s website. In addition, information posted on the Company’s website is subject to change without prior notice.

Investment Decisions

Information posted on the Company’s website is intended to assist in the understanding of the Company, and not intended to be a solicitation for investment. Investors are advised to make their own independent judgments regarding investment decisions.

Period of Silence

In order to prevent the leakage of financial statement information and ensure fairness, the Company has determined a “Period of Silence,” whereby the Company will refrain from making any comments or respond to questions regarding financial results during the period between the day immediately following the balance sheet date and the date on which the financial statements are made public.