Basic Policy on Information Disclosure

To provide information to shareholders and investors in a timely, accurate and fair manner, OPTEX GROUP Company, Limited complies with the Companies Act, the Financial Instruments and Exchange Act and other laws and regulations, promptly discloses information prescribed in the Rules on Timely and Appropriate Disclosure of Corporate Information by Listed Companies (the “Timely Disclosure Rules”), which has been established by Tokyo Exchange Inc., and other important information. In addition, the Company will proactively disclose information that is useful for an accurate understanding of the situation of the Company.

Methods of Information Disclosure

With respect to information disclosure, the Company discloses important corporate information in accordance with the Timely Disclosure Rules established by Tokyo Exchange Inc., and will disclose it on the Company’s website promptly after the completion of the public announcement regarding insider trading regulations under the Financial Instruments and Exchange Act. In addition, the Company discloses information that is not covered by the Timely Disclosure Rules in a timely and fair manner, in keeping with the principle of timely disclosure. Please note, however, that information posted on this website may be limited. In addition, expressions used for the information displayed on the website may vary from those used for the information disclosed using other methods.

Cases of refusal to disclose information

For reasons related to commercial transactions or for confidentiality purposes, etc., the Company may not respond to inquiries about specific information. In addition, the Company strictly refrains from revealing undisclosed important information.

Quiet Period

To prevent any leakage of information on financial results and to ensure fairness, the Company observes a quiet period of three weeks prior to the day of the announcement of the financial results. During this period, the Company refrains from responding to inquiries or commenting on financial results. However, in the event that the financial results confirmed during the quiet period differ so substantially from previously announced financial forecasts that the disparity is likely to be subject to the Timely Disclosure Rules, the Company discloses the information in an appropriate manner in accordance with the Rules.