Corporate Disclosure Policy

1. Information Disclosure Standards

Adventure, Inc. (hereinafter referred to as “the Company”) shall promptly disclose information in a timely manner based on transparency, impartiality and consistency in accordance with the Financial Instruments and Exchange Law and other laws and regulations, and the Timely Disclosure of Corporate Information (hereinafter referred to as the “Timely Disclosure Rules”) of the Securities Listing Regulations of the Tokyo Stock Exchange. The Company shall proactively and fairly disclose information that is deemed important or useful for shareholders and investors to understand the Company, even if such information does not fall under the scope of laws and regulations or timely disclosure rules. The Company shall not disclose personal information, customer information or information that may infringe on the rights of related parties.

2. Information Disclosure Method

Information required by the Timely Disclosure Rules shall be disclosed through the Timely Disclosure Network (TDnet) provided by the Tokyo Stock Exchange in accordance with the Rules and shall promptly be posted on the Company’s website after it has been disclosed through the TDnet. Any information deemed important or useful that does not fall under the scope of the Timely Disclosure Rules shall also be published on the Company’s website for extensive disclosure.

3. Insider Trading Prevention

Annual seminars on insider trading regulations are held for directors and employees and explanatory materials are distributed to raise the awareness and understanding of the purpose of insider trading regulations. The Company also issues internal notices to raise awareness of insider trading as deemed appropriate.

4. Business Forecast and Future Information Management Practice

Business forecasts, future prospects, strategies and targets disclosed by the Company, other than those relating to past or present facts, are forward-looking statements, which are based on plans, expectations and judgments in accordance with information currently available to the Company and certain assumptions deemed legitimate. Consequently, actual results may differ materially from the disclosed forecasts due to changes in economic trends and other various factors of uncertainty.

5. Quiet Period

The Company has designated the period from the day following the last day of the fiscal year (quarterly settlement of accounts) to the announcement date of each fiscal year as a Quiet Period from the perspective of preventing the leakage of financial information (including quarterly settlement of accounts information) and ensuring fairness in information disclosure. During this period, the Company reserves the right to refrain from answering questions or making comments regarding financial results and forecasts. Notwithstanding the aforesaid, in the event that there is an expectation of a significant variation in the earnings forecast during this period, the Company shall announce such information as appropriate in accordance with the Timely Disclosure Rules.

6. Internal Structure Development

In accordance to this Corporate Disclosure Policy, the Company is committed to developing and reinforcing internal systems and structures to ensure appropriate information disclosure in compliance with applicable laws and regulations and the Timely Disclosure Rules.