Basic Stance

Sumitomo Chemical regards respect for カジノ シークレット 入金 不要ights as part of the foundation for its business continuity. We are continuing to make a group-wide effort to address this as a material issue for management, and provide disclosures on our measures and progress. In order to accelerate its efforts on カジノ シークレット 入金 不要ights, Sumitomo Chemical formulated the Sumitomo Chemical Group カジノ シークレット 入金 不要ights Policy in April 2019, based on the Universal Declaration of カジノ シークレット 入金 不要ights, the International Labor Organization Declaration on Fundamental Principles and Rights at Work, the Ten Principles of the United Nations Global Compact, and the United Nations Guiding Principles on Business and カジノ シークレット 入金 不要ights. At the same time, we established the カジノ シークレット 入金 不要ights Promotion Committee, a committee tasked with promoting our カジノ シークレット 入金 不要ights initiatives. In order to pursue a group-wide effort to respect カジノ シークレット 入金 不要ights, we are committed to ensuring that all Group companies in Japan and overseas are fully aware of the カジノ シークレット 入金 不要ights Policy and take action on these principles.

Sumitomo Chemical Group カジノ シークレット 入金 不要ights Policy (Effective April 1, 2019)

This policy was formulated based on the advice of outside カジノ シークレット 入金 不要ights experts with practical experience.

Announcement of the Group Statement Based on カジノ シークレット 入金 不要ights Laws and Regulations

We at the Sumitomo Chemical Group, as a globally operating corporation, have announced a group statement on our efforts to address risks related to modern slavery and human trafficking in our business activities and supply chain. This statement is based on laws and regulations in various countries with regard to respect for カジノ シークレット 入金 不要ights and the prevention of modern slavery and human trafficking, including the Modern Slavery Act of the United Kingdom, the Modern Slavery Act of Australia, and the California Transparency in Supply Chains Act of the United States.

Management System

カジノ シークレット 入金 不要ights Promotion Committee

Sumitomo Chemical has established the カジノ シークレット 入金 不要ights Promotion Committee as its organization for promoting activities incompliance with the カジノ シークレット 入金 不要ights Policy. In order to plan and implement measures to respect カジノ シークレット 入金 不要ights across the entirevalue chain,^*1this committee consists of members from a broad range of related departments and functions. The senior executiveofficer in charge of corporate departments serves as chair, while from the business sectors, executive officers responsible for thePlanning & Coordination Offices^*2of their respective departments participate as committee members.

1. Value chain is defined by ISO 26000, which is an international standard related to social responsibility, as an “entire sequence of activities or parties that provide or receive value in the form of products or services.” See below for details.
2. The Planning & Coordination Offices are departments in charge of matters related to the planning, technologies, and development of each business sector.

カジノ シークレット 入金 不要ights Promotion Committee

Group-wide Approach

Based on its basic policy for respect for カジノ シークレット 入金 不要ights, Sumitomo Chemical continues to take various measures to promote respect for カジノ シークレット 入金 不要ights by working closely with its Group companies in Japan and overseas, while also engaging business partners.

Overseas, in particular, we are working with our regional headquarters in Europe, the Americas, China, and the Asia-Pacific region to ensure and promote compliance, including initiatives to protect カジノ シークレット 入金 不要ights, based on our compliance system that we have established in accordance with respective local legal systems of the countries where we operate.

Examples of Initiatives

カジノ シークレット 入金 不要ights Due Diligence and Relief Efforts

With the aim of promoting respect for カジノ シークレット 入金 不要ights in its business activities, the Sumitomo Chemical Group has establisheda system for カジノ シークレット 入金 不要ights due diligence in accordance with the United Nations Guiding Principles on Business and HumanRights. Under our approach to evaluating, reducing, and preventing カジノ シークレット 入金 不要ights risks, not only for Sumitomo Chemical itself and its supply chain, but also for Group companies in Japan and overseas and their supply chains, we set priorities based onpotential カジノ シークレット 入金 不要ights risks, and implement our efforts in steps. The Sustainability Department, Legal Department, ProcurementDepartment, and Logistics Department collectively serve as our secretariat office for カジノ シークレット 入金 不要ights due diligence, working withbusiness sectors and other relevant departments to ensure that our entire value chain is assessed.

External specialists conduct カジノ シークレット 入金 不要ights risk evaluations of the Group to evaluate, reduce, and prevent カジノ シークレット 入金 不要ights riskswithin the Group.

Moreover, for the supply chain, we rank priorities based on assumed カジノ シークレット 入金 不要ights risks, conduct surveys, and promoteengagement. As a comprehensive initiative, we ensure the effectiveness of カジノ シークレット 入金 不要ights risk reduction initiatives by includingclauses related to the implementation of カジノ シークレット 入金 不要ights-related initiatives in new and existing agreements. As a practical riskreduction initiative, we distributeThe Sumitomo Chemical Group Supplier Code of Conduct^* and collect responsesto Check Sheets and カジノ シークレット 入金 不要ights questionnaires, which independently confirm the status of initiatives by each supplier, thereby determining the status of general sustainability measures andmanagement systems, including those related to カジノ シークレット 入金 不要ights, at suppliers (supplier due diligence, hereinafter “supplier DD”).In addition, for suppliers of raw materials that have a high risk of having a negative impact on カジノ シークレット 入金 不要ights (high-risk rawmaterials), we conduct high-risk raw material due diligence (DD) through surveys that track to the source.

If it is discovered through these activities that any negative impacts on カジノ シークレット 入金 不要ights are occurring because of our Group’s business activities, or have been fostered by the Group’s business activities, we will redress or resolve those incidents through theappropriate procedures, in collaboration with related stakeholders.

• Reviewed the Sumitomo Chemical Group Sustainable Procurement Guidebook, revised and retitled the Sumitomo Chemical Group Supplier Code of Conduct in August 2022.

カジノ シークレット 入金 不要ights Due Diligence Overview of Initiatives

Approach to Our カジノ シークレット 入金 不要ights Due Diligence Efforts

Sumitomo Chemical Group Company Management

Sumitomo Chemical Group Company Management Flow

Initiatives in FY2022

Since it is important to regularly assess カジノ シークレット 入金 不要ights risks in response to changes in social conditions and other factors, we conducted a カジノ シークレット 入金 不要ights risk assessment (second round) for the Company and 131 consolidated management companies (as of October 2022). With the cooperation of outside カジノ シークレット 入金 不要ights experts, we estimated potential カジノ シークレット 入金 不要ights risks for each company based on the business activities, location (country/region), personnel composition, raw materials/products handled, and other factors of the group companies. We also confirmed the status of risk measures based on interviewing with personnel in charge and the results of internal audits and responsible care audits. Through these processes, we conducted an assessment more closely attuned to reality while maintaining objectivity.

Risk Evaluation Items

For this risk assessment, we first set the four categories of society, environment, occupational safety and health, and governanceas major focal areas, and for each category, we determined items in detail for assessing risks. For example, in the category of “society,” we selected such diverse items as forced labor, child labor, discrimination, harassment, freedom of association, indigenouspeople, and cultural heritage. In other categories, we conducted risk assessment as to those items that we had addressed inaudits, by examining them from a カジノ シークレット 入金 不要ights perspective.

Policy for Calculating Risk Scores

Regarding each item, we confirm activities as factors either contributing to or reducing risk. When there are activities that couldbecome risk factors, we add to the risk score, and when there are activities that reduce risk factors, we subtract from the risk score,thereby quantifying risk. The higher the risk score, the higher the カジノ シークレット 入金 不要ights risk.

Examples that add to the risk score

• Employing foreign national workers and migrant workers
• Operational region of the Group company ranked as a high-risk country in indices published by international institutions
  (for example: the Global Child Forum & UNICEF’s Children’s Rights and Business Atlas)
• Businesses considered labor-intensive (business categories considered to have a relatively high ratio of low-wage workers)

Examples that subtract from the risk score

• Confirming the personal IDs of migrant workers and storing copies
• Formulating policies related to prohibiting child labor
• Confirming the provision of employee wages in an amount adequate to provide for a family and meet basic needs, suchas food and housing

Points Updated for the Second Round of カジノ シークレット 入金 不要ights Risk Assessments

We considered the following factors to ensure that changes in social conditions are appropriately reflected.

• Country-specific indicators newly formulated and released by international organizations
• Among raw materials being handled, the presence or absence of materials that are considered to have high カジノ シークレット 入金 不要ights risks,such as conflict minerals
• Problematic rises in cases of カジノ シークレット 入金 不要ights violations in the chemical industry and in countries where Group companies are based
• The addition of the safety and health field to the ILO’s Core Labor Standards

FY2023 Initiative Plans

As a result of the カジノ シークレット 入金 不要ights risk assessments, we conduct detailed investigations using written surveys and the input of outside カジノ シークレット 入金 不要ights experts for Group companies that are considered to urgently need their status confirmed. We will confirm the facts and take remedial measures as needed.

Supply Chain Management

Supply Chain Management Flow

A. Introducing カジノ シークレット 入金 不要ights Clauses into Contracts

In fiscal 2020, we have formulated contract provisions that request understanding of and cooperation with our efforts to respect カジノ シークレット 入金 不要ights, and have begun including them in our contracts with our business partners, including raw material suppliers, materials and equipments suppliers, logistics providers, and contract manufacturers.
We will not only continue to sign contracts that include these カジノ シークレット 入金 不要ights provisions, we will also respond in line with the procedures defined in these カジノ シークレット 入金 不要ights provisions when negative impacts on カジノ シークレット 入金 不要ights occur in our supply chain, or under the apprehension that such an impact has occurred.

B. Supplier DD

The Sumitomo Chemical Group is committed to building mutually beneficial and sound relationships with its business partners.We ourselves do business in a fair, equitable and transparent way, while also promoting sustainable procurement efforts acrossthe entire supply chain with respect for カジノ シークレット 入金 不要ights and a firm commitment to compliance. In order to encourage our businesspartners to work on sustainability efforts,in the Sumitomo Chemical Group Supplier Code of Conduct, we ask our business partners to respect カジノ シークレット 入金 不要ights, prohibit complicity with カジノ シークレット 入金 不要ights violations, prohibit discrimination and harassment, respect basic rights related to labor, prohibit forced labor and child labor, comply with the minimum wage, and assurance of a living wage. In addition, to accurately recognize the risk status related to legal compliance and ethics, society, occupational safety and health, and the environment in the procurement of raw materials in the supply chain, we send the Sumitomo Chemical Group Supplier Code of Conduct to our major business partners, collect the Sumitomo Chemical Group Sustainable Procurement Check Sheets filled out by each company, and confirm the status of initiatives.

Furthermore, from fiscal 2021, we are conducting detailed investigations of the Company's major business partners using questionnaires specialized for カジノ シークレット 入金 不要ights (the カジノ シークレット 入金 不要ights questionnaire). The カジノ シークレット 入金 不要ights questionnaire comprises two parts: one for the management system of the entire company and one with questions specialized for カジノ シークレット 入金 不要ights (the presence or absence of カジノ シークレット 入金 不要ights risks and the implementation status of risk reduction measures). We provide feedback on the results for all business partners who respond. And for those business partners that we would like to take further action, we engage with them on an individual basis (including exchange information related to sustainability initiatives and share the best practices of the Sumitomo Chemical Group, providing support as needed).

Excerpts of the カジノ シークレット 入金 不要ights Questionnaire

Major items	Examples of specific questions
Questions related tocompany-widemanagement systems	Numbers of employees, presence of labor unions, status of formulation of policies (for example: カジノ シークレット 入金 不要ights policies, legal and regulatory compliance, environmental conservation, occupational safety and health), supply chain management status (forexample: status of risk assessments for business partners and the supply chain), establishment of whistleblower hotline
Questions specially focused on カジノ シークレット 入金 不要ights*3 (for example: confirming forced labor risks for foreign national workers and migrant workers)	We collect responses to the following questions to confirm the risk of forced labor of foreign national workers and migrant workers. Employment status of foreign national workers and migrant workers Does the company use recruitment specialists when employing foreign national workers and migrant workers? If using recruitment specialists, is the company doing its due diligence to ensure the specialists’ business activities do notviolate the カジノ シークレット 入金 不要ights of job seekers? Has the company established an internal procedure for confirming whether recruitment specialists are collecting feesfrom job seekers? Before the planned worker departs their home country, does the company provide documents that clarify the main workingconditions (job duties, wages, workhours, etc.) in the worker’s native language or a language the worker can understand? Before the planned worker departs their home country, does the company explain necessary information related tothe country where they will work or the workplace (rules of the workplace, occupational safety and health, performance considerations, use of dormitory, helpdesk contact information if there are problems, etc.) in the worker’s native languageor a language the worker can understand?

1. We confirm a wide range of カジノ シークレット 入金 不要ights issues, such as child labor, forced labor, discrimination (responsible recruitment), and the rights of indigenous people.

Initiatives in FY2022

Based on the fiscal 2022 survey results of the カジノ シークレット 入金 不要ights questionnaire, we conducted engagement with major suppliers to gain their understanding of and cooperation on initiatives aligned with the United Nations Guiding Principles on Business and カジノ シークレット 入金 不要ights. In addition, we revised the Sumitomo Chemical Group Sustainable Procurement Guidebook to further pro- mote sustainability initiatives, including those related to カジノ シークレット 入金 不要ights, among suppliers. We amended the guidebook into the Sumitomo Chemical Group Supplier Code of Conduct, incorporating respect for カジノ シークレット 入金 不要ights, prevention of complicity with カジノ シークレット 入金 不要ight violations, and assurance of a living wage.

FY2023 Initiative Plans

To confirm the status of initiatives in line with the Sumitomo Chemical Group Supplier Code of Conduct, we will continue promoting sustainable procurement in the supply chain by sending major suppliers the Sumitomo Chemical Group Sustainable Procurement Check Sheets and questionnaires specialized for カジノ シークレット 入金 不要ights, collect responses, and take improvement measures as necessary.

C. High-risk Raw Material DD

The Sumitomo Chemical Group formulated the “カジノ シークレット 入金 不要l Group Policy for Responsible Procurement of Minerals/Raw Materials” in March 2020 to further promote efforts prohibiting the procurement of conflict minerals. Under the policy, the Groupdefines high-risk raw materials as those that having a high probability of negatively impacting カジノ シークレット 入金 不要ights in the supply chain,including, but not limited to, tantalum, tin, gold, tungsten, cobalt, mica, graphite, and pulp. Depending on the characteristics ofthe high-risk raw materials, we promote initiatives aligned with the premise of the OECD Due Diligence Guidance for ResponsibleSupply Chains of Minerals from Conflict-Affected and High-Risk Areas (the OECD Guidance).

Initiatives in FY2022

From fiscal 2020, in line with the Sumitomo Chemical Group Policy for Responsible Procurement of Minerals/Raw Materials, we conducted surveys of the usage status of high-risk raw materials at the Company and Group companies in Japan. As a result, we determined that we need additional confirmation for some of the raw materials source.

FY2023 Initiative Plans

Regarding some of the raw materials mentioned above, we will conduct additional confirmation. As a result of the confirmation, if there are concerns, we will consider remedial measures to reduce カジノ シークレット 入金 不要ights risks in line with the Sumitomo Chemical Group Policy for Responsible Procurement of Minerals/Raw Materials and continue implementing necessary initiatives. In addition, for business partners that handle high-risk raw materials, we will continue requesting reports based on the Responsible Minerals Initiative (RMI), steadily promote risk assessments, and consider rolling these efforts out to overseas Group companies.

Grievance Mechanisms

We have grievance mechanisms in place in the form of the Speak-Up Reporting System (whistle-blowing channels) in orderto address concerns about activities that may adversely impact カジノ シークレット 入金 不要ights or any other concerns raised about our businessactivities. These channels are available for anyone involved in Sumitomo Chemical Group’s business activities, including theirbusiness partners as well as Sumitomo Chemical Group Personnel and their families.

In addition, regarding harassment in particular, Sumitomo Chemical has established a harassment consultation office andconsultants. We have set up systems to provide consultations for employees regarding various types of harassment, includingpower harassment, sexual harassment, maternity harassment, and SOGI harassment.^*4

Each of these aforementioned consultation offices accepts anonymous consultations and whistleblower reports. In the Compliance Manual, we make clear that the Company gives utmost consideration to protecting the privacy of the reporting person and maintaining the confidentiality of information provided and that the Company does not put people at any disadvantage, such as through dismissal, transfer, or discrimination, on the grounds of having received a consultation or made a report. We are raising awareness of these facts among employees.

Furthermore, at all aforementioned offices, in fiscal 2022, there were no confirmed cases related to discrimination and nomajor negative impact on カジノ シークレット 入金 不要ights affecting the business continuation of the Group.

The Group will continue working to more effectively operate grievance mechanisms going forward.

1. SOGI harassment: harassment related to sexual orientation and gender identity

Education and Awareness Raising

Our basic policy of respect for カジノ シークレット 入金 不要ights is articulated in our Compliance Manual (Sumitomo Chemical Code of Business Conduct) and also communicated across through our intranet. In addition, our labor-management agreement makes it clear that an employee who damages the work environment for other employees through sexual speech and behavior, harassment, or other similar actions is considered violating our work regulations and thus subject to disciplinary action.
Under these principles, we value respect for an individual’s personality, prohibiting any action to disrespect or disparage an individual’s personality taken based on personal emotions or values or any harassment, bullying or similar speech or action.
We also prohibit all kinds of harassment, including power harassment and sexual harassment (including harassment of a person of the same gender and harassment of LGBTQ people regarding sexual orientation and gender identity).
In addition, we prohibit discrimination and do not allow any discriminatory action that is taken for reasons of employment type, age, gender, birthplace, ancestry, nationality, race, disability, religion, beliefs, marital status, or other such attributes and harms an individual’s dignity. We particularly make it clear that discrimination based on gender or a difference in sexual orientation or gender identity and discrimination against people with disabilities are prohibited.

Raising Employees’ Awareness of カジノ シークレット 入金 不要ights

To ensure that each employee correctly understands and is fully aware of カジノ シークレット 入金 不要ights issues, Sumitomo Chemical incorporates カジノ シークレット 入金 不要ights in its employee education. We highlight カジノ シークレット 入金 不要ights not only in the introductory training in which all employees participate after joining the Company but also in many other internal training programs, such as those for newly promoted employees (when promoted to a higher grade or a manager position) and those for recruiting interviewers.
In addition, we regularly implement awareness-raising training and initiatives at each site of our operations and each Group company.

Initiatives to Raise Awareness of カジノ シークレット 入金 不要ights (Sumitomo Chemical Group)

Name and format	Purposes	Boundary	FY	Sessions	Participants	Participation rate
Seminars and lectures on human rights Training based on the Sumitomo Chemical Group カジノ シークレット 入金 不要ights Policy	Preventing harassment and discrimination on the grounds of gender and against socialminorities and カジノ シークレット 入金 不要ightsviolations Preventing child labor, forcedlabor, and human trafficking etc.	Sumitomo Chemical	2022	98	8,703 (cumulative total)	131.1
		Sumitomo Chemical Group (42 major Group companies in Japan)	2021	147	7,261 (cumulative total)	78.2

Note: The participation rate is calculated as the cumulative total of participants.

We provided opportunities for all Sumitomo Chemical Group management executives and employees to learn about business and human
rights through a website specifically for the JIRI-RITA ACTION, which is aimed at helping employees promote sustainability.
A total of 25,000 people took courses offered on the website, where they learn about the Company’s policies and initiatives related to カジノ シークレット 入金 不要ights issues, such as modern slavery by answering questions.

Engaging in カジノ シークレット 入金 不要ights Initiatives

Stakeholder Engagement Program Hosted by Caux Round Table Japan

Since fiscal 2019, Sumitomo Chemical has participated in the Stakeholder Engagement Program hosted by Caux Round Table Japan, a non-profit organization, to better understand what circumstances can cause カジノ シークレット 入金 不要ights issues and how business activities are related to カジノ シークレット 入金 不要ights, as well as material カジノ シークレット 入金 不要ights issues and the importance of considering カジノ シークレット 入金 不要ights in business activities.
This program invites companies, non-government and non-profit organizations, and experts to discuss カジノ シークレット 入金 不要ights due diligence that is required by the Guiding Principles on Business and カジノ シークレット 入金 不要ights. The subject for fiscal 2022 was “カジノ シークレット 入金 不要ights Issues by Sector” formulated by the Nippon CSR Consortium in fiscal 2021. Participants engaged in sectoral discussion, referring to the カジノ シークレット 入金 不要ights guidance tool created by the United Nations Environment Programme Finance Initiative (UNEP FI). (We participated in the discussion for the chemical, construction material, and manufacturing sectors.)

カジノ シークレット 入金 不要ights Due Diligence Subcommittee Hosted by Global Compact Network Japan

Since fiscal 2019, Sumitomo Chemical has engaged in the カジノ シークレット 入金 不要ights Due Diligence Subcommittee hosted by the Global Compact Network Japan in order to promote カジノ シークレット 入金 不要ights due diligence based on the Guiding Principles on Business and カジノ シークレット 入金 不要ights.
In fiscal 2022, the subcommittee organized various initiatives such as seminars by experts and workshops related to カジノ シークレット 入金 不要ights due diligence. We will continue to deepen our understanding of カジノ シークレット 入金 不要ights by engaging in various initiatives, and leverage the learning in the Group’s カジノ シークレット 入金 不要ights promotion efforts.

Others

Signed onto the Declaration of Partnership Building

Sumitomo Chemical supports the premise of the “Council on Promoting Partnership Building for Cultivating the Future” promoted by Japan’s Cabinet Office and the Small and Medium Enterprise Agency and announced our Declaration of Partnership Building. This initiative aims to encourage the collaboration of large companies with small and medium-sized companies, promote measures to enhance productivity across the entire supply chain, and build mutually beneficial relationships between large companies and small and medium-sized companies. In its declaration, Sumitomo Chemical not only clarifies as one of its individual items that it will conduct trade in a manner that ensures fairness and transparency but also clarifies that it emphasizes カジノ シークレット 入金 不要ights and compliance and is promoting sustainable procurement initiatives throughout the supply chain to enforce sustainability initiatives at suppliers.

Consideration for カジノ シークレット 入金 不要ights in Investment

Along with interviews and legal due diligence for investment candidates, before acquisition we confirm consideration for カジノ シークレット 入金 不要ights issues, response status, and the systems of investees.

Initiatives for the Rights of Children

The Sumitomo Chemical Group focuses efforts not only on eliminating child labor in Japan and overseas but also on educational support regarding respecting the rights of children.

Looking Ahead

We at the Sumitomo Chemical Group will observe our カジノ シークレット 入金 不要ights Policy and work together as one to continue our efforts led by the カジノ シークレット 入金 不要ights Promotion Committee to promote respect for カジノ シークレット 入金 不要ights.