Komori
Occurring Fact3930Hatena Co.,Ltd.Information and Communications, Services and Others

Notice Regarding the Formulation of Measures to Prevent Recurrence

In response to the incident involving an outflow of funds resulting from fraudulent payment instructions, the Board of Directors resolved measures to prevent recurrence by strengthening approval procedures for fund transfers, authority management, accounting operations, information security, internal audits and governance. Some of these measures have already been introduced and put into operation.

Worth reading
55In focus
0–100. This measures how worthwhile something is to read, not how good or bad the company is.
Direction
Improvement
Direction inferred from the company’s description.
Scale
—
Displayed only when the document provides numerical figures.
Wording
Conditional
How definitive the wording is.

Formulation of measures to prevent recurrence

Subject Entity

Hatena Co.,Ltd. (the filing company)

Target Locations / Products

Company-wide fund transfer and payment processes, accounting operations, information security, and internal audit and governance frameworks

Occurrence31 July 2026 (date of the Board of Directors' resolution)
This disclosure07/31/2026
Cause

An incident involving an outflow of funds resulting from fraudulent payment instructions. The reason for formulating measures to prevent recurrence was the recommendations in the investigation report of the Special Investigation Committee.

Company response

Investigation structure

References the investigation report of the Special Investigation Committee. The name of the committee chair and the date of establishment: not disclosed

Measures to prevent recurrence

(1) Strengthening internal controls over fund transfer and payment processes: clarifying fund transfer rules; introducing prior, multi-stage approval through workflows and verification of supporting documentation; reviewing user authorities; separating payment application authority from approval authority; restricting the environment in which approval operations may be performed; setting the maximum payment amount at the minimum necessary level; and using automatic notification functions. (2) Improving the visibility of accounting operations and establishing appropriate segregation of duties: reviewing key accounting operations; preparing operating manuals; clarifying management and control functions and operational functions; and restructuring the organizational framework. (3) Strengthening information security management and education for officers and employees: restricting the use of remote desktop tools; establishing an advanced security environment for terminals used to handle funds; thoroughly communicating and inspecting password management rules; and providing ongoing training on special fraud techniques and reporting procedures when suspicious incidents occur. (4) Strengthening the internal audit and governance frameworks: strengthening the framework through measures including establishing a dedicated internal audit structure and using external experts; increasing the Audit & Supervisory Board's risk awareness; and enhancing cooperation with the internal audit department and the accounting auditor. (5) Establishing continuous monitoring and reporting frameworks: building a system for the Board of Directors and the Compliance and Risk Committee to continuously monitor the establishment and operation of measures to prevent recurrence

Directors' and officers' liability

The disclosure states that management takes its responsibility for this incident seriously. Compensation reductions, resignations and disciplinary action: not disclosed

Outlook

The Company will implement the measures to prevent recurrence, establish and operate an appropriate funds management framework, further strengthen governance, and work to restore trust and sustainably enhance corporate value.

Event that occurred
ItemDetails
Event nameFormulation of measures to prevent recurrence
Date of occurrence31 July 2026 (date of the Board of Directors' resolution)
Subject EntityHatena Co.,Ltd. (the filing company)
Target Locations / ProductsCompany-wide fund transfer and payment processes, accounting operations, information security, and internal audit and governance frameworks
CauseAn incident involving an outflow of funds resulting from fraudulent payment instructions. The reason for formulating measures to prevent recurrence was the recommendations in the investigation report of the Special Investigation Committee.
Investigation structureReferences the investigation report of the Special Investigation Committee. The name of the committee chair and the date of establishment: not disclosed
Measures to prevent recurrence(1) Strengthening internal controls over fund transfer and payment processes: clarifying fund transfer rules; introducing prior, multi-stage approval through workflows and verification of supporting documentation; reviewing user authorities; separating payment application authority from approval authority; restricting the environment in which approval operations may be performed; setting the maximum payment amount at the minimum necessary level; and using automatic notification functions. (2) Improving the visibility of accounting operations and establishing appropriate segregation of duties: reviewing key accounting operations; preparing operating manuals; clarifying management and control functions and operational functions; and restructuring the organizational framework. (3) Strengthening information security management and education for officers and employees: restricting the use of remote desktop tools; establishing an advanced security environment for terminals used to handle funds; thoroughly communicating and inspecting password management rules; and providing ongoing training on special fraud techniques and reporting procedures when suspicious incidents occur. (4) Strengthening the internal audit and governance frameworks: strengthening the framework through measures including establishing a dedicated internal audit structure and using external experts; increasing the Audit & Supervisory Board's risk awareness; and enhancing cooperation with the internal audit department and the accounting auditor. (5) Establishing continuous monitoring and reporting frameworks: building a system for the Board of Directors and the Compliance and Risk Committee to continuously monitor the establishment and operation of measures to prevent recurrence
Directors' and officers' liabilityThe disclosure states that management takes its responsibility for this incident seriously. Compensation reductions, resignations and disciplinary action: not disclosed
OutlookThe Company will implement the measures to prevent recurrence, establish and operate an appropriate funds management framework, further strengthen governance, and work to restore trust and sustainably enhance corporate value.
Items this document does not state (16)
Date recognized / date notice receivedAmount of Impact on Business PerformanceAccounting period in which recognizedImpact on Earnings ForecastType of litigation or proceedingCourt or authorityPlaintiffDefendantDate of filing / date of actionClaim amount / surcharge amountAmount of receivables at risk of non-collection or delayed collectionSuspended operationsScheduled resumption dateVoting rights ownership percentage before the changeVoting rights ownership percentage after the changePlanned follow-up disclosure

These are items the company does not state in this document. We do not leave them blank, nor fill them in from other sources or by inference.

The reasons the company gives

The company's own explanation, not something inferred from the numbers.

The resolution was made in response to the recommendations in the investigation report of the Special Investigation Committee concerning the incident involving an outflow of funds resulting from fraudulent payment instructions, which was announced on 24 April 2026.

How to read this page

This is not the documentKomori reads the disclosure the company filed and writes this summary. Figures are as stated by the company and are not audited.
Weight is not a verdictIt measures how much this changes what the company had already told the market. It is not a view on the shares.
Corrections happenIf the company reissues this disclosure, the page is rebuilt from the corrected version and the revision number moves up.
Notice Regarding the Formulation of Measures to Prevent Recurrence | Hatena Co.,Ltd. (3930) timely disclosure | Komori