Disclosure Policy

The ENEOS Group conducts business activities based on its mission, stated in the ENEOS Group Philosophy, to "contribute to the development of our communities and help to ensure a vibrant future through creation and innovation in energy, resources, and materials."
We have established this policy as a guideline for the accurate and easy-to-understand disclosure of important information.

1. Basic Policy

ENEOS Holdings, Inc., ("the Company") fully recognizes that adequate and timely disclosure of company information is a cornerstone of sound capital market formation. The Company shall endeavor to expeditiously, appropriately, and impartially disclose information to shareholders and investors to establish a highly transparent corporate management.

2. Compliance with Applicable Laws and Regulations

The Company complies with applicable laws and regulations in the countries and regions where it conducts its business activities. In addition, the Company has established Insider Trading Prevention Regulations and has put in place a system to ensure all employees are fully aware of the regulations.

3. Disclosure Standards

The Company shall disclose material information, including information about financial results, and decisions and events likely to influence investment decisions, in compliance with applicable laws and regulations including the Companies Act, the Financial Instruments and Exchange Act and other laws and regulations, and the Tokyo Stock Exchange and other exchanges' rules on timely disclosure of corporate information by issuers of listed securities ("Timely Disclosure Rules"). In addition to information required to be disclosed by the Timely Disclosure Rules, the Company shall also proactively disclose other information in response to the needs and wishes of shareholders and investors.

4. Group Systems and Procedures for Timely Disclosure of Company Information

As the ENEOS Group's holding company, the Company oversees the management of ENEOS Group companies. The Company shall establish systems and procedures to expeditiously and accurately gather, manage, and disclose information about not only itself but also ENEOS Group companies.
A flowchart of the ENEOS Group's timely disclosure procedures is appended below.

5. Information Disclosure Methods

Information to which the Timely Disclosure Rules apply shall be disclosed by the Company via the Tokyo Stock Exchange's TDnet information disclosure system. In addition, after disclosure, the Company shall promptly post the same information on its website.
For information not subject to disclosure per the Timely Disclosure Rules, the Company shall accurately and impartially communicate the information to shareholders and investors in accordance with the above Basic Policy and Disclosure Standards.

6. Quiet Periods (periods during which inquiries on financial results are declined)

To prevent information leaks concerning financial results, the Company shall observe quiet periods for three weeks before it publicly reports its financial results. During quiet periods, the Company shall refrain from answering any questions or otherwise commenting about its financial results. However, if a substantial deviation from the Company's previously announced earnings forecast comes to light during a quiet period, the Company shall disclose such information.

7. Applicable Scope

This policy applies to all officers and employees, etc., of the ENEOS Group. All business partners involved in the ENEOS Group's business activities will be requested to cooperate with this policy.

8. Positioning

This policy supplements the provisions of the ENEOS Group Philosophy and the ENEOS Group Code of Conduct.

(Appendix) Flowchart of Timely Disclosure Procedure

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