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Disclosure Policy

1. Basic Policy

Cosmo Energy Holdings Co., Ltd. (hereinafter referred to as the “Company”) aims to become a company trusted by all stakeholders, while pursuing our fundamental management philosophy of actively disclosing not only financial and other important corporate information related to management in a timely and appropriate manner, but also information related to non-financial matters.

2. Information Disclosure Standards

The Company seeks to disclose information in accordance with the Companies Act, Financial Instruments and Exchange Act (including the Fair Disclosure Rule), and other laws, as well as the rules on the timely disclosure of company information stipulated in the Tokyo Stock Exchange's (hereinafter the “TSE”) Securities Listing Regulations (hereinafter the “Timely Disclosure Rules”). At the same time, the Company will actively disclose information that is not subject to these Acts and other laws as well as the Timely Disclosure Rules, if the Company deems it effective for facilitating understanding of the Company.

3. Information Disclosure Methods

In principle information subject to the Timely Disclosure Rules is published promptly on the Company's website following registration in the Timely Disclosure Network (TDnet) provided by the TSE. Information that is not subject to the Timely Disclosure Rules is also openly announced via various media, including the Company's website.

4. Prevention of Insider Trading

The Company has stipulated internal rules for the appropriate handling of important corporate information and the prevention of insider trading and is working to promote a thorough understanding and awareness of these rules by employees across all Company groups.

5. Handling of Earnings Forecasts and Future Information

Any non-historic fact disclosed in the Company's plan, earnings forecasts and business targets is provided on the grounds of a decision or assumption made based on the information available at the time, while actual earnings results may vary significantly due to various factors.

Factors that could impact business results include, but are not limited to, changes in general economic conditions, crude oil prices, the supply and demand situation and fluctuations in the prices of petroleum products, as well as currency exchange rate fluctuations.

6. Quiet Period (Period of Restricting Information Disclosure)

As a general rule, the Company observes a “quiet period” (of around one month) from the day following the end of the fiscal period to the earnings results announcement date in each quarter in order to prevent the divulgence of important corporate information and to ensure fairness. During this period, the Company will refrain from responding to or making comments on questions related to the business results for the quarter. With regard to inquiries pertaining to information that is already publically available, the Company shall respond as usual, even during the quiet period. If any event that arises during a quiet period is subject to timely disclosure requirements, however, the Company will disclose the information as appropriate.

7. Development of Internal Systems/Structures

In the event that any decision is made by the Company, or any fact arises with respect to the Company, based on a thorough examination by the Legal and General Affairs Departments, if disclosing information is deemed necessary under the Timely Disclosure Rules, it will be promptly published on TSE's network, subsequent to discussions and approvals by the Board of Directors' and the Executive Officers' Committee meetings. The Company's Corporate Communications Department will disclose information extensively, even when it is not subject to the Timely Disclosure Rules, through the media or on the Company's website in accordance with the policy outlined in Item 1 above. With respect to the disclosure of information related to Environmental, Social and Governance (ESG), Sustainability Strategy Meeting, an organization chaired by the Group Chief Executive Officer of Cosmo Energy Holdings Co., Ltd. which sets the non-financial policies and indicators, will scrutinize the information from diverse perspectives.

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