Hitachi Construction Machinery

Global

Disclosure Policy

1. Basic Policy

Hitachi Construction Machinery (HCM) seeks to maintain and develop trust relationships with its stakeholders, including shareholders and other investors, customers, business partners, employees and regional communities based on the HCM’s corporate credo. It will fulfill its responsibility to stakeholders by disclosing information in a fair and highly transparent manner, and by conducting various communication activities.

2. Information Disclosure Standards

HCM discloses information as appropriate in a fair and highly transparent manner, in compliance with the law and/or regulations of the stock exchanges on which the Company is listed.

HCM discloses not only information required by law and/or regulation, but also management and financial information it regards as useful in deepening stakeholder understanding of HCM management policy and business activities. HCM also discloses non-financial information regarding the social and environmental impact of its activities. HCM’s stance on disclosure recognizes that society regards the above information as important.

3. Disclosure Methods

HCM uses appropriate means to disclose the information required by law and/or regulations of the stock exchanges on which the Company is listed. The Company also posts this information on its website immediately after it is disclosed.

HCM also discloses information not required by law and/or regulations by distributing news releases, holding press conferences and presentations, posting information on its website, and conducting other disclosure activities in an appropriate, precise and timely manner.

4. Quiet Period

HCM stipulates a quiet period of a certain length prior to earnings announcements to prevent information leaks and to maintain disclosure fairness. During this period, HCM refrains from answering inquiries about business performance and related matters.

5. Forward-looking Statements

In its disclosures, HCM may make statements that constitute forward-looking statements that reflect management’s views with respect to certain future events and financial performance at the time of disclosure and include any statement that does not directly relate to any historical or current fact. Such statements are based on information available at the time of disclosure and are subject to various risks and uncertainties. Certain forward-looking statements are based upon assumptions of future events which may not prove to be accurate. HCM discloses the factors that could cause actual results to differ materially from those projected or implied in forward-looking statement.