Investor Presentaiton
Material Information - The "De Minimis"
Threshold
The type of information that is considered "material" may not require you to wait until legal
"disclosure" if such information falls within one of the "de minimis" categories set forth in the Cabinet
Order regarding Trading of Securities, etc. (i.e., as being information that may only have a minor effect
on the investment decisions of investors).
"De minimis" threshold:
If the amount of damages anticipated will be less than an amount equivalent to 3% of the net assets of
the Listed Company as of the last day of the most recent financial year, then you can trade before
disclosure by the company.
"Disclosure" means:
12 hours have passed since the Listed Company made disclosure of the material nonpublic
information through two press institutions (daily newspapers or broadcast media);
the Listed Company has delivered the information to its share exchange (such as the Tokyo Stock
Exchange) and the exchange has made such information available for public inspection (Tdnet:
(https://www.release.tdnet.info/inbs/l_main_00.html)); or
the relevant material nonpublic information is disclosed in a public securities filing such as a
securities registration statement (EDINET: http://disclosure.edinet-fsa.go.jp/).
Morgan Lewis
Summary of the Insider Trading Regulations of Japan
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