The TOPIX is designed to reflect the composition of the Japanese equity market, and it has evolved thoughtfully across many decades, from the rise of export manufacturing, to the emergence of consumer electronics and software, to the 2022 market restructuring. In each era, TOPIX has been refined to better represent the investable universe of contemporary Japan, and we are grateful for the care with which the Exchange has approached that responsibility.

Benchmarks work best when they apply consistent standards across all their constituents and represent the investable universe as fully as possible. When new categories of issuers emerge, our view is that these existing principles serve the index better than category-specific rules would. Applying the same eligibility standards to all companies, without regard to the specific composition of their balance sheets, is what allows a benchmark to remain trusted and representative over time.

One of our guiding key performance indicators is Bitcoin per share, alongside the development of our operating businesses. Every capital markets action we undertake is directed toward advancing that measure for our shareholders. Our corporate strategy combines this disciplined treasury approach with the development of a portfolio of operating businesses, several of which are active or under development. Currently these include our Bitcoin income generation business, the building of Bitcoin infrastructure in Japan through our Project Nova initiatives, and Bitcoin ecosystem investments through Metaplanet Ventures, in addition to our hotel and media related businesses.

We should be understood not as a passive investment vehicle, but as an operating company with an integrated strategy, and our shareholders are not purchasing undifferentiated exposure to a digital asset. They are investing in a Japanese operating company with a deliberate corporate strategy, and expressing confidence in its management and direction. We ask that the Exchange evaluate Metaplanet on the basis of its business model, financial performance, and operational characteristics, as it does for all other TOPIX constituents.

The TOPIX today includes many constituents with highly concentrated exposure to a single commodity, a single product line, or a single end-market. Upstream oil and gas issuers trade in close correlation with hydrocarbon prices. A number of the most heavily weighted constituents in the semiconductor equipment sector derive nearly all of their revenue from a single category of capital equipment, and have experienced very large swings in share price across successive cycles. Approximately 10% of listed Japanese companies hold more than 50% of their total assets in cash and cash equivalents. The index has long accommodated such concentrations while maintaining its role as a representative benchmark of the Japanese equity market. By market capitalization, companies adopting a Bitcoin treasury strategy would represent a small share of TOPIX, and their effect on overall index behavior would be correspondingly modest.

If balance-sheet concentration is a topic the Exchange wishes to study further, we believe it may be more appropriate to examine this on a principled and consistent basis across the full range of constituents, rather than by reference to a single asset class. Index neutrality, in our view, calls for consistent treatment across asset classes.

Japan has taken a thoughtful and constructive stance on crypto assets. On December 10, 2025, the Working Group on Crypto-Asset Systems of the Financial System Council published its report setting out a direction for bringing crypto assets within Japan’s regulated financial framework, reflecting their growing role as investment assets and giving due consideration to both investor protection and the promotion of innovation. On January 5, 2026, at the Tokyo Stock Exchange’s New Year ceremony, the Minister of Finance expressed support for developing exchange-based infrastructure for digital assets, pointing to the established frameworks of supervision and investor protection of regulated exchanges. On April 10, 2026, the Cabinet approved an amendment to the Financial Instruments and Exchange Act that will bring approximately 105 crypto assets under FIEA oversight as financial instruments. The FY2026 tax reform further aligns crypto taxation with other financial instruments through a 20% capital gains rate and a three-year loss carryforward, conditional on enactment of the amendment.

These developments reflect a deliberate national policy direction: to integrate crypto assets into Japan’s regulated financial system, with appropriate investor protections. We believe it is beneficial when index policy remains broadly consistent with the direction of national regulatory developments, and that the Exchange is well placed to help ensure they remain aligned, in a way that supports both investor protection and continued innovation in Japan’s capital markets.

We recognize that the Tokyo Stock Exchange will appropriately formulate its approach with primary reference to the context of Japan’s own capital markets, regulatory framework, and investor base. We offer the global context that follows as a reference point only, not as a template.

Among major global benchmark providers, the treatment of listed companies holding significant crypto assets has been considered recently through formal public consultation and through the application of existing eligibility rules. In January 2026, MSCI, following its own public consultation, determined not to adopt a blanket exclusion of Digital Asset Treasury companies from its global indexes, while indicating that it would continue to study the category. Other benchmark providers have addressed the question through the application of their existing frameworks, producing a range of outcomes that collectively reflect a preference for transparent, criteria-based judgments rather than relying solely on categorical approaches.

The Tokyo Stock Exchange is uniquely placed to determine the framework most suited to Japan, and the direction of global peers is relevant only to the extent the Exchange finds it instructive. We offer this information in the hope it may be a useful input to the Exchange’s deliberations.

We acknowledge that the Exchange’s careful consideration of this matter reflects legitimate concerns around volatility, disclosure practice, and investor protection. We share those concerns and are committed to addressing them through enhanced disclosure, governance, and risk management practices. We believe such concerns are best addressed through transparent, criteria-based standards rather than categorical exclusion.

To that end, we welcome dialogue with the Exchange on additional disclosure standards it may consider appropriate for companies with significant crypto-asset holdings, including independent custody verification, proof-of-reserves, risk disclosures, and governance frameworks. Metaplanet publishes audited financial statements, maintains a majority of independent outside directors on its board, and has invested substantially in both Japanese and English disclosure and investor communication. Higher standards, applied transparently and consistently, would strengthen confidence in the category as a whole, and would reinforce the Exchange’s broader mission of developing Japan’s capital markets and advancing investor protection.