Teijin Group Sustainability Website Content 2021

Sustainability

Teijin Group Anti-Corruption Policy
Teijin Limited established "Teijin Group Anti-Corruption Policy" in September, 2021 and established anti-corruption
procedures and systems.
Teijin Group Anti-Corruption Policy
The Teijin Group is committed as its corporate philosophy to enhancing the quality of life through a deep insight into human nature andneeds, together with the application of creative abilities. Corruption is against the Group's corporate philosophy and totally
unacceptable as it leads to violations of human rights, distorts the market and erodes the quality of life. Therefore, we (Note 1) hereby
establish the "Teijin Group Anti-Corruption Policy".
1. Fundamental Principles
In this policy, "corruption" refers to the abuse of entrusted power for an improper gain, including but not limited to all forms ofcorruption, such as extortion, bribery (Note 2), conflicts of interest (Note 3), and illicit receipt of rebates and kickbacks. We recognizethat the prevention of bribery is a particularly important issue for us. Thus, we strictly prohibit any direct or indirect involvementwith bribery in violation of applicable laws and regulations. In addition, we do not permit any facilitation payment that is made forthe purpose of obtaining an improper gain (Note 4).
We comply with all applicable anti-corruption laws and regulations. We prohibit any direct or indirect involvement with corruption
in violation of laws and regulations. We meet our stakeholders' expectations by sincerely working to combat corruption through ourbusiness activities.
Furthermore, we broadly promote fair business practices and strive to contribute to the realization of peaceful, just, and inclusivesocieties.
2. Implementing a compliance program under the commitment of top management
The Teijin Group CEO will assume full responsibilities for taking necessary measures to implement this policy in the Teijin Group,including; repeatedly communicating this policy both inside and outside the company; maintaining and allocating appropriate theauthority and resources to the Chief Social Responsibility Officer; and establishing a group compliance program that includes
procedural rules and organizational structure.
3. Adopting a risk-based approach
To identify corruption risks within the Group, we assess risks from various aspects including the nature of our business operation,
our business relationship, and our products or services and the scale and location of our business activities. We will take priority
measures on the business activities with a high risk of corruption.
4. Education and training
We establish and implement a system for conducting regular education and training on the implementation of this policy and therelated procedures for Group officers and employees.
5. Third party due diligence
We prohibit not only direct involvement with corruption but also the involvement through third parties such as sales agents. We
strictly control contracts and transactions with third parties such as agents and develop procedures for monitoring third party
activities regularly in order to prevent any involvement in corruption through a third party.
6. Effective operation of the whistleblowing hotline system
We establish and implement an effective whistleblowing hotline system that allows all the officers and employees to make a reportwhenever they become aware of corruption. We keep confidentiality of these reports and prohibit any disadvantageous treatmentagainst the reporters.
7. Appropriate responses when any misconduct is identified
If corruption is detected or suspected, we prudently investigate any allegation, analyze the root cause of the misconduct, and takeremedial actions to prevent recurrence. Any officers and employees who were involved in corruption shall be subject to strict
disciplinary actions regardless of their positions.
8. Control measures before and after mergers and acquisitions

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We carry out due diligence of any target company from a perspective of corruption risk prior to mergers and acquisitions as well as
business alliances. We also integrate the company's compliance program into that of our Group through the post-merger
integration.
9. Monitoring and continuous verification / review
We regularly monitor the implementation of this policy, verify its effectiveness and, if necessary, review it under the supervision ofthe Board of Directors.
10. Recording and reporting our efforts
We keep accurate records in our accounting books to avoid any doubt of our involvement in corruption. We also endeavor todisclose our anti-corruption efforts to the extent possible recognizing that anti-corruption is an important concern for both internaland external stakeholders.
Note 1"We" refers to the Teijin Group and its officers and employees.
Note 2"Bribery" refers to any payment of money, any provision of entertainment, gifts, or any other benefit, any payment of expenses, any donations or subsidies,etc. to public officials, etc. (including private citizens when commercial bribery is prohibited) in order to obtain an improper gain in violation of any applicablelaws and regulations. This includes cases where we receive bribes in violation of any laws and regulations.
Note 3"Conflict of interest" refers to a situation in which any individual or company is confronted with conflicts between the duties and demands of their position
and their own private interests.
Note 4"Facilitation payment" refers to a small amount of payment to public officials, etc. for the purpose of facilitating procedures related to ordinary
administrative services.

Resolution by the Board of Directors of TEIJIN LIMITED on September 30, 2021
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Sustainability

Main Activities
The Teijin Group provides conduct standard for preventing corruption in the Teijin Group Corporate Ethics Handbook andthoroughly informs employees about those standards.

In addition, entertainment with public institutions such as governmental organizations is in principle prohibited, but in cases of transactions
with public institutions, when payment is made for benefits such as entertainment and gifts or donations are provided with a reasonable basis,prior approval by the designated responsible person is required.
In addition, we perform due diligence to confirm the eligibility of potential business partners from the perspective of preventing corruption
conducted by external partners. We also conduct appropriate due diligence of target companies when conducting corporate acquisitions toconfirm that there is no past or current corruption. We require new business partners to comply with our CSR procurement policies including
the prohibition of bribery.
While taking these measures, we regularly conduct compliance education and training relating to anti-corruption and conduct internal audits.

FY2020 Activity Results
Risk assessment
In FY2019, we conducted assessments of the domestic and overseas sales functions of each Teijin group company in order to study the exposureof the risk of corruption throughout the entire group companies. The results did not identify any sales departments with significant corruption
risks. In business with public institutions including governmental organizations, however, it was recommended that development ofmanagement systems and regular and proper trainings be conducted preferentially in accordance with Teijin Limited fundamental policies,
taking into consideration characteristics at the site of business.
In FY2020, we confirmed the rules for preventing corruption in all business divisions.

Education
At the June 2020 CSR Committee meeting, we held an anti-corruption compliance lecture conducted by an outside attorney. Training with thesame content was conducted for compliance personnel in each division.

Status of violations of laws and regulations relating to corruption
There were no incidents resulting in employee discharge or the imposition of legal measures for corrupt conduct in FY2020.

Future Issues
We periodically conduct internal audits and risk assessment surveys and assess and review (the PDCA cycle) management systems for theprevention of corruption so that we can maintain ongoing and effective management in accordance with rules.
In addition, we will encourage Group employees who encounter corruption and other risks to make extensive use of consultation hotlines andreporting systems, and for outside business partners, we will proceed with development in stages including education and the creation ofchannels for the provision of information.

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Status of the Provision of Capital
In principle, the Teijin Group does not make political donations. In the case of expenditures necessary for the conduct of business, however,donations may be made within the scope of relevant regulations and in accordance with the Regulations for Teijin Group Responsibilities andAuthorities. No direct donations were made to specific political parties in FY2020.
Also, within the Teijin Group, Teijin Pharma Limited, which engages in the pharmaceutical business, established a policy relating totransparency in relationships with medical institutions and discloses the status of the provision of funds to such organizations in accordancewith that policy.
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