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: "To comply with laws and regulations while maintaining the highest ethical standards." 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.

Sumitomo Corporation Group Compliance Policy

Based on the "Sumitomo Corporation Group Compliance Policy", as a member of Sumitomo Corporation Group, we place compliance at the center of our corporate management in performing our daily business activities.

Guiding Principles for Compliance

1. Fair Competition
We must promote fair competition through our business activities while always complying with the laws and regulations relating to anti-trust and fair competition.

2. International Trade Regulations including Security Trade Control
We must comply with applicable laws and regulations as well as international treaties with respect to import and export control, security trade control and customs.

3. Laws Relating to Your Business
We must always study, fully understand and comply with the laws and regulations relating to our business.

4. Accuracy of Company Books and Records; Tax Compliance
We must maintain true and accurate books and records in a timely manner and properly retain all related documents. We must pay taxes and fulfill our tax reporting obligations in compliance with the applicable laws and regulations and the Sumitomo Corporation Group Tax Principles.

5. Anti-Bribery and Anti-Corruption
We must always stay committed to undertaking strict measures to prevent birbery, improper provision of benefits and other forms of corruption. We must never commit bribery or conduct any activity which may raise the suspicion of bribing a government or other public official of any country, municipality or region. We must not offer, provide, or promise to provide cash or cash equivalents, gifts, entertainment or anything of value to public officials for the purpose of improperly obtaining or retaining business. In the event that you receive a request from a public official for such an act, you must reject the request and the company will contact the relevant authorities as the situation demands. We must comply with domestic and foreign laws and regulations concerning anti-bribery and anti-corruption applicable to our business activities.

6. Intellectual Property Rights
We must protect the intellectual property ("IP") rights of the Sumitomo Corporation Group and we must also respect the IP rights of others.

7. Information Management
We must properly manage the confidential information of the Sumitomo Corporation Group as well as the confidential information received from our business partners to prevent any unauthorized disclosure or use of such confidential information.

8. Environmental Protection
We must comply with the Sumitomo Corporation Group Environmental Policy and place great importance on protecting the global environment, while striving to achieve sustainable development through sound business activities.

9. Insider Trading
We must not engage in any conduct which violates, or which may have the appearance of violating, the laws and regulations on insider trading.

10. Respect for Human Rights and Prevention of Discrimination and Harassment
We must respect the human rights of others and not tolerate any discrimination or harassment.

11. Conflicts of Interest
We must always act in the best interest of the Sumitomo Corporatino Group. We must never use company assets or our positions at our company to pursue our own or a third party's interests at the expense of the Group's interests.

Compliance Committee

The members of our compliance committee are as follows:

Chairman Representative Director and President
Vice-Chairman Corporate Officer in charge, Responsible for Corporate Division
Secretariat General Manager, Human Resouces and Coordination Group
General Manager, Risk Management and Corporate Legal and Logistics Group
Committee Members General Manager, Internal Auditing Dept.
General Manager, Corporate Administration Dept., No. 1
General Manager, Corporate Administration Dept., No. 2
General Manager, Corporate Administration Dept., No. 3
General Manager, Corporate Administration Dept., No. 4
General Managers of Sales Divisions
Observer Corporate Auditor

Company Information

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