Mitsubishi Chemical HoldingsTHE KAITEKI COMPANY

Disclosure Policy

1. Statement of Commitment

Mitsubishi Chemical Holdings Corporation (MCHC) intends to engage in further enhancement of management transparency, prompt and appropriate disclosure of any information on the MCHC Group, and active, constructive dialogue with stakeholders such as shareholders, investors, customers, business partners, and local communities so as to build and maintain relationships of trust with all of them.

2. Disclosure Policy

With respect to material information as stipulated by the timely disclosure standards and the fair disclosure rules, including that regarding decisions, events, and earnings results that may have an impact on the investment judgement of shareholders and investors, MCHC discloses information in accordance with standards in the Securities Listing Regulations established by the Tokyo Stock Exchange (“timely disclosure standards”) as well as Article 27-36 of the Financial Instruments and Exchange Act (“fair disclosure rules”), etc. In addition, MCHC will actively disclose information that is deemed valuable to shareholders and investors, even if it is not material information as stipulated by the timely disclosure standards and the fair disclosure rules.

3. Methods of Disclosure

MCHC discloses information in accordance with fair disclosure rules. Information will be made public through the Timely Disclosure Network (TDnet) provided by the Tokyo Stock Exchange and, promptly after such public disclosure, made available via press releases and the MCHC website. Information other than above will also be disclosed in a manner appropriate for the content.

4. Internal System Related to Disclosure

The information for disclosure will be centrally controlled by the Public Relations and Investor Relations Office, and the General Manager of the office will serve as the person in charge of information disclosure

(1) Disclosure of material information stipulated in the timely disclosure standards and fair disclosure rules

The Public Relations and Investor Relations Office will cooperate with each relevant department to discuss the necessity for disclosure of information that may be applicable for the above-mentioned “2. Disclosure Policy,” report the result to the executive in charge of investor relations, and disclose it as necessary.

(2) Information disclosure other than mentioned above

The Public Relations and Investor Relations Office will cooperate with each relevant department for disclosure of information other than above mentioned, and disclose it as necessary.

5. Disclosure to Capital Market Participants and Dialogue with Shareholders and Investors

(1) Handling of Forward-Looking Information

When MCHC discloses business forecasts and future prospects related to management strategies, research and development, etc., the company discloses them with cautionary statements, giving due consideration to the facts that they are based on the currently available information and certain assumptions judged as rational; that they include known or unknown risks and uncertainties; and that a number of factors could cause actual results to differ materially from those described in such forward-looking statements.
In principle, MCHC will refrain from commenting on opinions, recommendations, or business forecasts regarding the MCHC Group made by third parties. However in some case, when not responding could have serious ramifications for the capital market and the company and in consideration of the need to provide stakeholders with true and accurate information, MCHC will disclose the information in a timely and appropriate manner.

(2) Avoidance of Selective Disclosure

Selective disclosure is the disclosure of material information mentioned in “2. Disclosure Policy” above, to any individual or group prior to the broad public dissemination of that information. Selective disclosure is against MCHC's policy unless the people or groups to whom nonpublic information is disclosed are covered by confidentiality or nondisclosure agreements.

(3) Quiet Period

In order to prevent the leaking of earnings-related information (including quarterly financial results) and ensure fairness, MCHC has established a quiet period from the day after the last day of the financial period for the fiscal year or quarter to the day of the announcement of the financial results. During this period, MCHC will refrain from responding to questions or commenting on said earnings. However, when there is material information mentioned in “2. Disclosure Policy” above, including events during the quiet period that may differ significantly from MCHC’s announced earnings forecast, the company will disclose such information in a timely and appropriate manner. That said, MCHC will respond to questions during the quiet period regarding previously announced information.

(4) Responding to Uncertain Information

In principle, MCHC will refrain from commenting on market rumors and speculations regarding the MCHC Group. However in some cases, MCHC may disclose information in a timely and appropriate manner when not responding could have serious ramifications for the capital market and the company.

6. Corrections to this Disclosure Policy

Any corrections to this Disclosure Policy must be made by attaining the approval of the executive in charge of investor relations.