To further increase our corporate values and achieve sustainable growth in the future, it is absolutely imperative for us to comply with not only laws and regulations but also internal rules in all aspects of our management of the company. Compliance is clearly defined in the Action Guidelines of Sumitomo Corporation: ""comply with laws and regulations while maintaining the highest ethical standard."" We place the utmost importance on it in our management. We have a compliance committee to reinforce our compliance system and promote educational activities so that the compliance-based mindset will be deeply rooted and extensively disseminated among all of our officers and employees in their daily work.
In the event anyone should infringe a rule, it is assured that it will be immediately reported to his/her supervisor or relevant departments. In addition to the reporting system through the organizational ladders, we have introduced a ""speak up"" system by which any trouble can be reported directly to the compliance committee, thereby enabling the company to swiftly take the best cource of action.
As a member of Sumitomo Corporation Group, we place compliance at the center of our corporate management in performing our daily business activities.
The members of our compliance committee are as follows:

Compliance Committee

ChairmanRepresentative Director and President
Vice-ChairmanCorporate Officer in charge of Corporate Division
SecretariatGgeneral Manager, Human Resouces Group
General Manager, Risk Management and Legal Group
Committee MembersGeneral Manager, Internal Auditing Office
General Manager, Corporate Administration Dept. No.1
General Manager, Corporate Administration Dept. No. 2
General Manager, Corporate planning & Coordination Dept.
General Manager, CHUBU Branch
General Managers of Sales Divisions
ObserverCorporate Auditor

Guiding Principles for Compliance

As a member of the Sumitomo Corporation Group, we follow the compliance policy as set forth in the "Sumitomo Corporation Compliance Manual."

Ⅰ Business Activities.

1. Observing Antimonopoly Laws

Employees shall not engage in private monopolization, unreasonable restraint of trade or unfair trade practices.

2. Security Trade Control

Employees shall not provide to any foreign country any weapons, arms or related technology that might disturb the maintenance of international peace and security.

3. Customs/Controlled Items

Employees shall carry out customs clearance procedures properly with respect to all items exported or imported. Employees shall not export or import any controlled items.

4. Compliance with Applicable Laws

Employees shall become familiar with the applicable laws relevant to their individual business responsibilities in order to have an appropriate understanding of such laws, and shall refrain from engaging in any conduct that violates such laws.

5. Respecting and Protecting Intellectual Property Rights

Employees shall not engage in actions that may infringe the intellectual property rights of others and shall protect the intellectual property rights of the Company, which are among its valuable corporate assets.

6. Prohibition of Unfair Competition

The Management Principles of the Company place prime importance on integrity. Employees shall not engage in any practices constituting unfair competition, which may damage the reputation of the Company.

7. Information Management

The Company's confidential information, including without limitation customer information, trade secrets and know-how, is a valuable corporate asset of the Company. Employees shall treat the Company's confidential information with great care and keep it in strict confidence. Confidential information received by the Company from a third party shall be treated with the same degree of care.

8. Preservation of the Environment

Employees shall give due consideration to the preservation of the global environment.

9. Overseas Business Activities

When conducting business overseas, employees shall familiarize themselves with the local laws and regulations governing their activities and act in compliance with these laws and regulations.

Ⅱ Corporate Citizen As a Member of Society.

10. Prohibition on Giving Bribes

Employees shall not engage in any conduct which would constitute, or has the appearance of, the offering of any bribe. Employees are also prohibited from giving gifts or offering entertainment to government officials.

11. Prevention of Unlawful Payments to Foreign Governmental Officials

Employees shall not provide or offer to provide any unlawful benefit, including without limitation cash, to any foreign governmental official for the purpose of procuring business.

12. Political Contributions

Employees shall not make any political contributions that are not in compliance with applicable law.

13. Confrontation with Antisocial Forces

Employees shall not yield to any antisocial forces and shall take a strong stand to oppose any such influence.

Ⅲ Maintenance of a Good Working Environment.

14. Respect for Human Rights (*)

Employees shall respect human rights and shall not engage in any unfair discrimination.
* Complied with the Universal Declaration of Human Rights.

15. Prohibition of Sexual Harassment

Employees shall not engage in sexual harassment, including any sexually offensive actions or remarks that have a negative impact on the working environment.

16. Prohibition on Abuse of Authority

Employees shall exercise their authority in the workplace within the appropriate scope and shall not use their authority to engage in harassment of any other employee, including comments, actions or gestures that may damage another employee's dignity or character, create a harmful working environment for another employee or cause another employee to fear losing his or her employment.

17. Prohibition on harassment regarding pregnancy, childbirth, child rearing, or caregiving

Words or actions in the workplace are prohibited that damage the work environment of female workers that are pregnant or give birth, or male or female workers that apply for or receive absence from work due to child rearing or caregiving.

Ⅳ Personal Interests.

18. Insider Trading

Employees shall not engage in any conduct that violates, or may appear to violate, the laws and regulations regarding insider trading.

19. Conflict of Interest

Employees shall not engage in any conduct which conflicts with the interests of the Company.

20. Proper Use of Information System

Employees shall not use the information system of the Company for any unauthorized purpose.