Basic Policy
TeamSpirit Inc. (hereinafter “the Company”) strives to disclose information accurately, fairly, and timely to all stakeholders including shareholders and investors in accordance with the Financial Instruments and Exchange Act of Japan and other applicable ordinances as well as the Timely Disclosure Rules designated by the Tokyo Stock Exchange. Aside from such information, the Company also seeks active disclosure of information that is considered to be beneficial in understanding the Company.

Disclosure Methods
Disclosure of information subject to the Timely Disclosure Rules is carried out on the Timely Disclosure Network provided by the Tokyo Stock Exchange (TDnet), while disclosure of annual securities reports, quarterly reports and other documents required under Financial Instrument Exchange Act, etc. are made on the Electronic Disclosure System provided by the Financial Services Agency (EDINET). Any information thus disclosed is also promptly announced on the IR page of the Company’s website. In addition, the Company also makes efforts to actively and fairly disclose information that is not covered in the Timely Disclosure Rules in adhering to the timely disclosure principle and the intent of the fair disclosure rules under the Financial Instruments and Exchange Act, if the Company believes it to be of use to its stakeholders.

Quiet Period
To prevent the leakage of financial results information and from the perspective of ensuring fairness of information disclosure, the Company has set a quiet period which begins from the day following the end of a fiscal period (fiscal quarter) and ends on the day financial results are announced. During this period, the Company shall refrain from responding to or making comments on questions regarding its financial results and earnings forecasts. However, the Company will make announcements as appropriate and in a timely manner in the event of a material fact which the Company determines may affect investors’ decisions, or if such information is required to be disclosed under relevant laws and Timely Disclosure Rules.

Prevention of Insider Trading
The Company sets forth internal rules and regulations to prevent any potential insider trading, and strives to educate our directors and employees about such rules and regulations in proper manner. In addition, the Company puts forth substantial efforts to prevent insider trading by appropriately controlling material undisclosed information that could affect investors’ decisions, and appropriately disclosing applicable information in accordance with relevant laws and Timely Disclosure Rules.

Development of Internal Structure
In accordance with this IR Policy, the Company strives to improve and strengthen our internal management system in order to provide appropriate information disclosure in accordance with relevant laws and Timely Disclosure Rules.