Information Disclosure

With growing demand for corporate transparency and accountability, we recognize the increasing importance of accurate and timely information disclosure for stakeholder and the significant impact of a company's approach to information disclosure and communications on the establishment of its corporate brand. In regard to information disclosure, Article 10 of the Sumitomo Electric Group Charter of Corporate Behavior advocates the importance of “disclosure of relevant information and promotion of communication with society.” The Article states that the Sumitomo Electric Group will aim to provide appropriate corporate information to adequate collaboration with stakeholders, including shareholders, and that the Group will promote good communication with society through public information and hearings. Based on the Charter, Sumitomo Electric established and published its Disclosure Policy in September 2006, which stipulates Sumitomo Electric Group’s basic attitudes and policies regarding information disclosure.

Sumitomo Electric Group Disclosure Policy

1. Timely and appropriate disclosure of material corporate information
The Sumitomo Electric Group will work to disclose material corporate information* to customers, shareholders, investors, and other stakeholders in a timely and appropriate manner, observing the Financial Instruments and Exchange Act and other relevant laws and ordinances, as well as the Rules on Timely Disclosure of Corporate Information by Issuer of Listed Securities and the Like (hereinafter referred to as the “Timely Disclosure Rules”), stipulated by the stock exchanges on which the Company’s stock is listed.
* Material corporate information is defined here as corporate information that must be disclosed under the Financial Instruments and Exchange Act and other relevant laws and ordinances and as corporate information whose timely disclosure is required by the Timely Disclosure Rule

2. Voluntary information disclosure
The Sumitomo Electric Group will also promote voluntary disclosure of information that does not correspond to “material corporate information” so that our customers, shareholders, investors, and other stakeholders may deepen their understanding of the Sumitomo Electric Group.

3. Fair information disclosure
The Sumitomo Electric Group will work to disclose our corporate information in a fair manner through press releases to the media, our Company's website, publications, and other means while observing the relevant laws and ordinances as well as the Timely Disclosure Rules.

4. Development of our in-house systems for disclosure
The Sumitomo Electric Group will work to develop and improve our in-house systems to disclose information in line with our Disclosure Policy.

Enhancement of
Information
Dissemination through
Mass Media, etc.

In accordance with the Sumitomo Electric Group Charter of Corporate Behavior, we have established a system in which information on occurred material facts and decisions is collected and confirmed by public relations sections in cooperation with relevant divisions so as to promote timely and accurate information disclosure. Furthermore, to strengthen the disclosure system, the Public Affairs Committee, as a company-wide organization, establishes rules on the disclosure of company information, conducts training and awareness-raising activities within the Group, and formulates measures to enhance our corporate brand value.

* Please see the following page for a list of our press releases. Press Release

Dissemination of
Information to
Shareholders and
Investors

Sumitomo Electric believes that an important goal of its investor relations is to notify market participants of accurate information in a timely and fair manner, so as to obtain an appropriate evaluation of our corporate value in the capital market.
The Company works to enhance communication with institutional investors and analysts on such occasions as briefings on financial results and interviews. Opinions and issues identified through the dialogue are regularly reported to the Board of Directors while appropriately managing information. For general shareholders and investors, we post a wide range of information on our websites, including financial information, press releases and materials distributed in financial result briefings as well as relevant video images.
We will continue to engage in constructive dialogue with shareholders and investors to a reasonable extent and strive to disclose information in a fair, prompt and comprehensive manner.