(Subject to Corporate Governance Code Principle 5.1 issued by Tokyo Stock Exchange)

  1. Wacom Co., Ltd. (“the Company”) considers maintaining readiness for constructive dialogue with investors including shareholders as one of the most important issues for corporate management, and the Chief Executive Officer (“CEO”) shall officially take ultimate responsibility.

  2. In addition to the CEO, the Chief Financial Officer (“CFO”) shall be in charge of investor relations, and the Company shall organize a specialized unit for investor relations (“IR”). The CFO shall be an information officer who gathers necessary information by deepening cooperation with related units of the Company and its subsidiaries (“Wacom”).

  3. The CEO, CFO and IR employees shall be direct points of contact for constructive dialogue with investors to encourage understanding of Wacom’s corporate value, through providing both financial and business information as well as non-financial information such as Wacom’s corporate philosophy (Vision and Mission), code of conduct (Value), business model, corporate governance, strategies and execution plans, and risk management.

  4. The Company shall ensure accurate and fair disclosure. The company shall take prompt actions for statutory disclosure in compliance with the Companies Act and the Financial Instruments and Exchange Act, as well as timely disclosure in compliance with related rules set by Tokyo Stock Exchange.

  5. For dialogue with investors, the Company shall proactively seek opportunities with shareholders with large equity interest, as well as address dialogue requests from other investors to the best of the Company’s ability. Specifically, the Company shall select appropriately from the following methods for engaging in dialogue, after taking timing and location of investors into account. Depending on necessity, other senior management including outside board members shall also engage in dialogue.

  6. For dialogue with institutional investors, the Company shall not only hold one-on-one meetings but also small and/or large meetings with multiple investors. To encourage investment by non-Japanese resident institutional investors, the Company shall engage in investor conferences held outside Japan and/or visit these investors regularly.

  7. For dialogue with individual investors, the Company shall hold information sessions and/or engage in investor events to encourage understanding and investment in the Company.

  8. The Company shall carefully review analyses and comments received from investors regarding the management of Wacom, and apply this feedback as appropriate in working proactively to raise corporate value.

  9. The Company shall always send more than one person to attend dialogue with investors to prevent the exchange of insider information. Prior to each quarterly earnings release, the CEO and CFO shall discuss with related units including IR the content of disclosure and policy for dialogue with investors post release. Through this discussion, the CEO and CFO shall ensure that the dialogue does not contain insider information and that the content and level of detail of explanations are consistent for all investors to maintain readiness for accurate and fair disclosure.

  10. To obtain information about substantial shareholders not registered on the Company’s shareholders list, the Company shall conduct a shareholder identification survey twice a year, and encourage the effective and efficient implementation of constructive dialogue with domestic and foreign investors.

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Wacom received the "2007 Disclosure New Face Award" and the "2011 Disclosure Award" by Tokyo Stock Exchange, and the "2012 Best IR Award for Small to Medium Sized Capitalization Companies" by Japan Investor Relations Association.

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