MANAGEMENT

DISCLOSURE POLICY

1. Information Disclosure Standards

ROXX, Inc. aims to disclose information to shareholders and investors in a fair, timely and appropriate manner. In addition to information that complies with the Financial Instruments and Exchange Act, other laws and regulations, and the timely disclosure rules (the "Timely Disclosure Rules") established by the Tokyo Stock Exchange, we will actively disclose information that we deem important in relation to our business activities.

2. Method of Information Disclosure

Information subject to timely disclosure under the Timely Disclosure Rules is disclosed through the Timely Disclosure network (TDnet) provided by the Tokyo Stock Exchange, while securities reports, quarterly reports, and other disclosures required by the Financial Instruments and Exchange Act are disclosed through the Electronic Disclosure for Investors' NETwork (EDINET) provided by the Financial Services Agency.

Even for information that is not subject to timely disclosure under the Timely Disclosure Rules, Visional, Inc. will disclose information that it determines to be useful to shareholders and investors as actively and fairly as possible in an appropriate manner, based on the purpose of the applicable Fair Disclosure Rules.

3. Quiet Period

In order to prevent the leakage of financial information and to ensure fairness, we have established a quiet period that begins on the day following each quarterly financial closing date and ends on the day of the announcement of the quarterly financial results.

During this period, we will refrain from answering questions or commenting on our financial results or earnings outlook. However, if, during this quiet period, we anticipate a significant change in our earnings forecast, or if we are required to disclose information in accordance with applicable laws, regulations, or the Timely Disclosure Rules, we will make an announcement as appropriate in accordance with such laws, regulations, or the Timely Disclosure Rules.

4. Prevention of Insider Trading and Fair Information Disclosure

In order to prevent insider trading, we have established appropriate internal rules and regulations, and promote awareness and understanding of such rules and regulations among all officers and employees. In addition, we are working to prevent insider trading by appropriately managing relevant information regarding material facts that may affect investment decisions and promptly disclosing information in accordance with applicable laws and regulations and the Timely Disclosure Rules.

5. Establishment of Internal Systems

In accordance with this Disclosure Policy, ROXX, Inc. is striving to improve and enhance its internal systems to ensure appropriate disclosure of information in compliance with the Financial Instruments and Exchange Act, other applicable laws and regulations, and the Timely Disclosure Rules.

6. Others

When viewing Visional, Inc.'s information on the IR website, please refer not only to this Disclosure Policy but also to the disclaimers and other precautionary language that may be separately disclosed.