Disclosure Policy

Panasonic endeavors to ensure high levels of transparency in our business activities and fulfill our accountability to our stakeholders, acting pursuant to our basic philosophy of "a company is a public entity of society." We clearly define our basic policy on information disclosure in the "Panasonic Code of Conduct," our guideline for putting our Basic Business Philosophy into practice. We also publish relevant practical standards, methodologies, internal processes, etc., as our "Disclosure Policy," pursuant to which we proactively pursue constructive dialogues with our shareholders and investors.

1. Information disclosure (As stated in the "Panasonic Code of Conduct")

(1) Basic approach to information disclosure
We will provide our various stakeholders, including customers and shareholders, with fair and accurate information on corporate financial affairs, our Basic Business Philosophy, business policies and activities, as well as corporate social responsibility activities, in a timely, understandable and appropriate manner. At the same time, we will listen to our customers' requests and comments and reflect them in our business policies and activities. We will seek to be an enterprise with high transparency.
(2) Compliance with applicable laws and regulations
Our securities have been listed on securities markets in several countries and regions. Accordingly, we will abide by all applicable securities and information disclosure-related laws and regulations of appropriate countries and regions. We will never engage in insider trading or other transactions using inside information.
(3) Disclosure methods
In addition to information whose disclosure is required by securities-related laws and regulations of relevant countries and regions, we will disclose other information following proper internal control procedures, so as to ensure that the information we disclose is fair, accurate, sufficient and timely.

2. Information disclosure standards

We will abide by all applicable laws and regulations, and we will ensure the timely and appropriate disclosure of the information we are required to release under the Financial Instruments and Exchange Act, the Timely Disclosure Rules of the Tokyo Stock Exchange, and other laws and regulations, etc., that are applicable to the disclosure of our information ("Relevant Laws and Regulations"). We will also proactively disclose to our shareholders and investors, for the purpose of promoting constructive dialogues with them, any information which are not required to disclose under the Relevant Laws and Regulations but may be necessary or useful.

3. How our information will be disclosed

Information required to disclose under the Timely Disclosure Rules will be published via the Timely Disclosure network provided by the Tokyo Stock Exchange (TDnet), and our securities reports and other mandatory reports will be published through the Electronic Disclosure for Investors' NETwork system provided by the Financial Services Agency (EDINET); in either case, the information and reports will also be made available on our website.
If we communicate to our shareholders and investors any information which we are not required to disclose under the Relevant Laws and Regulations but may be necessary or useful for them and which may affect their investment decisions, we will disclose it on our website in accordance with the purpose of the Fair Disclosure Rule prescribed in the Financial Instruments and Exchange Act.

4. Internal processes for information disclosure

We have established structures and control procedures for ensuring that information on our Group that are required to disclose under the Relevant Laws and Regulations will be promptly collected at our IR or accounting department and published in a fair, accurate, timely, and appropriate manner. In the process of preparation and confirmation of reports such as annual securities reports, quarterly reports, etc., the Disclosure Committee, which is comprised of general managers of the principal departments that handle relevant information, confirms the validity of the content of the descriptions and the appropriateness of the procedures concerning the disclosure under the supervision of the CEO and the CFO.

5. Information control and silent period

Pursuant to the above "Panasonic Code of Conduct," we have established the internal rule to prevent insider trading for all directors, executives, and employees of the Panasonic Group. Also, managements, including the CEO and personnel in the IR-related department are fully aware of the significance of handling insider information and other material information properly, adhering to the Fair Disclosure Rule prescribed in the Financial Instruments and Exchange Act, and promote to engage in fair dialogue to avoid conducting "selective disclosure*." In concrete terms, we set a "silent period" from 15 business days prior to the financial announcement until the day of the announcement. During this period, these personnel reserve comment on any remarks and questions about our financial results. Even outside the silent periods, we do not participate in so-called "preview interviews" about our financial results, and do not engage in dialogues about undisclosed financial outlook.
However, if we believe we need to change our financial outlook significantly during the silent period, or if any other circumstances occur during that period which we are required to disclose under the Timely Disclosure Rules, we will disclose the information in accordance with the Timely Disclosure Rules.

*"Selective disclosure" means to individually provide material nonpublic information to specific business partners, investors, security analysts or media, regardless of intention.

6. Responses to market rumors information

In general, we do not to make any comments on speculative information about our company. However, we will take appropriate action if we consider it necessary to give clarifications to our investors and shareholders or if we receive inquiries from the Tokyo Stock Exchange.

7. Responses to financial assumptions by third parties

In general, we do not to make any comments on third parties' assumptions about our financial performance. However, we will take appropriate action if we regard that remaining silent is not an appropriate course of action.

8. Handling of forward-looking information

When we disclose future plans and outlook, we will clarify that they reflect our assumptions and estimates based on the information available at the time of disclosure, that there are known or unknown risks and uncertainties and other variable factors, and that such plans and outlook may be affected by them.