Sumitomo Chemical Group Statement against Modern Slaveryand Human Trafficking
1. About the Statement
This statement is made pursuant to Part 6, Section 54 of the Modern Slavery Act 2015 (the UnitedKingdom), the Modern Slavery Act 2018 (Australia) and the U.S. California Transparency in Supply
Chains Act of 2010 with consideration for the requirements of the other laws and regulations in relation
to modern slavery, human trafficking, forced labor, child labor and respect human rights andconstitutes the slavery and human trafficking statement for Sumitomo Chemical (“SCC”) group ofcompanies in scope for purposes of such Acts (“SCC Group”) for the financial year ending March2020.

The statement is approved by the board of directors of SCC.

2. Our Business
SCC Group, comprising of 170 subsidiaries, operates businesses worldwide, including the United
Kingdom and Australia, in five sectors – petrochemical, energy & functional materials, IT-related
chemicals, health & crop sciences and pharmaceuticals – and provides products worldwide that
support a wide variety of industries and help people’s daily lives.

3. Our Supply Chain
As SCC Group’s supply chains span and cover worldwide, wherever it engages in business, SCC
Group considers that an appropriate management of the supply chains is vital for operating its
sustainable business.

4. Our Philosophy and Initiatives against Modern Slavery and Human Trafficking
A. Our Philosophy
With the Sumitomo Spirit as its cornerstone, SCC Group has steadily forged ahead for more than
100 years.

Sumitomo Chemical’s Corporate Philosophy is based on Sumitomo’s Business

Principles and is composed of the Business Philosophy, which integrates the company’s businessprinciples, mission and values; the Corporate Slogan and Statement, which outlines thecommitment and pride to be shared in common by directors, officers and employees; and theSumitomo Chemical Charter for Business Conduct, which lays out the code of behavior serving
as the basis for the Company’s compliance system.

B. Initiatives to Ensure Compliance by SCC Group and its Supply Chains
To ensure compliance with applicable laws, regulations and ethical standards against modern
slavery and human trafficking in SCC Group’s operation or its supply chains, SCC Group has
been vigorously carrying out the following initiatives.

(a) Policy
SCC Group has in place in each of the companies a code of conduct, which sets forth arequirement that all relevant personnel must respect human rights of others and comply withapplicable laws, regulations and ethical standards.
In April 2019, SCC Group has established the “Sumitomo Chemical Group Human Rights
Policy” based on the Universal Declaration of Human Rights, the International Labor
Organization Declaration on Fundamental Principles and Rights at Work, the Ten Principlesof the United Nations Global Compact and the United Nations Guiding Principles on
Business and Human Rights, that includes the prohibition of forced labor and child labor.

(b) Risk Assessment and Due Diligence
SCC Group has been undertaking a human rights due diligence, assessing and rectifying thehuman rights violation risk within its business activities in accordance with the Guiding
Principles on Business and Human Rights with the aim of ensuring respect for human rights
through business activities.

In the due diligence, first, SCC Group identifies human rights

risks within its business by establishing risk indicators based on the nature of our businessand the regional characteristics of the SCC Group’s business activities and scoring thoserisks.

Second, SCC Group, together with external experts, will conduct follow-up

investigations into those company and businesses that ranked high risk scores including
additional on-site investigations as necessary.
If, as a result of this human rights due diligence process, it is determined that the SCC
Group’s business activities may be causing or contributing to adverse human rights impact,
we will engage with relevant stakeholders and rectify and remediate such impact throughappropriate measures.

(c) Supply Chain Management
It is SCC Group’s policy to procure supplies such as raw materials and packaging materials
from suppliers that operate their business in a socially responsible manner, including
operating their business free from modern slavery or human trafficking.

SCC Group hasbeen encouraging the existing suppliers and future candidates to enhance their efforts on
Sustainability activities through various initiatives.
As part of these initiatives, SCC Group have set a procurement standard under which SCC
Group will preferentially procure from suppliers who are most active in Sustainabilityactivities.

This policy is set out in the Group Business Standard of Procurement, which

provides guidelines for procurement operating activities for SCC Group companies in Japanand overseas.

Also, SCC Group has compiled five categories in the Sumitomo ChemicalGroup Sustainable Procurement Guidebook. The second category of this Guidebook
prescribes “Human Rights and Labor” and expressly prohibits forced labor and child labor.
This Guidebook address further issues such as “Respecting human rights”, “Regulatingworking hours”, “Paying appropriate wages”.

This Guidebook establishes the overarchingguidelines encompassing our commitment to combating modern slavery and humantrafficking.
Furthermore, SCC has formulated the Sumitomo Chemical Group Sustainable Procurement
Check Sheets to enable suppliers to demonstrate their consistency with our Sustainability
policies.

SCC monitors the implementation of Sustainability measures by all new suppliers

and by current suppliers of raw materials, especially those who locates outside Japan, via
the Sustainable Procurement Check Sheets.
Every year, SCC monitors around 10 to 20 new suppliers and around 30 to 40 current
suppliers in cooperation with each group companies.

For suppliers who need to follow-up

on problems revealed by the monitoring, SCC Group provides feedbacks, including focusedrequests for improvement and providing guidance and training.

By seeking to raiseawareness and cooperate in ensuring responsible procurement, SCC Group aims to prosper
alongside our suppliers.

However, this monitoring process is not an independent andunannounced audit.
We are currently in the process of revising our standard contractual terms to incorporate ahuman rights clause that requires to promise and certify to comply with laws and regulations
in respect of management of human rights risk including prohibition of modern slavery,
human trafficking, forced labor and child labor.

(d) Compliance Education and Training
All companies of SCC Group have been devoting earnest efforts to ensure strict compliancewith applicable laws, regulations and ethical standards on modern slavery and humantrafficking, and periodically providing its members with educational training sessions byutilizing both face to face seminars and e-learnings.

(e) Speak-up System
SCC Group places high importance on building an internal system, in order to capture at an
early stage sign of compliance violation, including any concern of SCC Group’s businesshaving been involved in modern slavery or human trafficking, and to make those issued
detected are removed promptly and appropriate measures are taken swiftly.

SCC Group

has adopted a dual-channel Speak-Up System equipped with an internal Speak-Up hotline
and an external Speak-Up hotline, which accept reports not only from a headquarter of
Sumitomo Chemical Company, but also all Group companies as long as relevant laws of
their respective countries permit it.

Under the System, any employee can report any

violation or suspected violation of compliance to his or her company’s compliance committee
or other similar governing committee via either its internal hotline, or an external hotline.
External hotline is usually operated by an outside lawyer appointed by the company.
Suppliers in our supply chains or anyone having any involvement in the company’s businessactivities can also report their concerns. SCC Group, all combined, receive approximately
140 cases of speak-up reporting in total.

C. Corporate Social Responsibility Initiatives
To resolve serious global issues such as modern slavery and human trafficking, SCC Group
believes that it is important to collaborate with international institutions along with promoting its
own Sustainability initiatives against modern slavery and human trafficking.

For that reason,

since 2005, SCC Group has been participating in the UN Global Compact, an initiative that seeks
to advance universal principles (the “Ten Principles”) on human rights, labor, environment andanti-corruption.

Also, in light of the contributions made and its firm commitment, SCC Group haslater joined the UN Global Compact LEAD, an exclusive group of sustainability leaders fromacross all regions and sectors that represent the cutting edge of the UN Global Compact, when itwas launched in 2011.

Through these initiatives, the SCC Group will contribute to thesustainable development of society, and also help achieve the UN Sustainable Development
Goals (SDGs) that are to be resolved across the globe by 2030, which includes taking immediate
and effective measures to eradicate forced labor and end modern slavery and human trafficking
as one of the goals.

5. Looking Ahead
SCC Group believes that the promotion of respect for human rights and ensuring compliance withapplicable laws, regulations and ethical standards, including those relevant to modern slavery andhuman trafficking, is vital for operating its business in a sustainable manner.

As such, SCC Groupwill continue its initiatives as described above, to identify and address any issues associated withmodern slavery and human trafficking throughout its global operations and supply chains.

6. Process of Consultation
The SCC Group’s overall human rights program including modern slavery and human trafficking
initiatives are developed and implemented group-wide under the leadership of the Human Rights
Promotion Committee, which reports to the Board of Directors. Through the committee, a crossfunctional team together with the respective internal business units representing each businesssectors work closely together to integrate group level measures of accountability for promoting respectfor human rights risk including prohibition of modern slavery, forced labor and child labor and toembed our initiatives and supporting processes across the SCC Group.
1st April 2020

Keiichi Iwata
Representative Director & President, Sumitomo Chemical Company, Limited