Tokuyama Group Human Rights Policy
1. Basic Approach to Human Rights
The Tokuyama Group considers respect for human rights to be the basis for all its businessactivities. In order to fulfill its corporate responsibility to respect human rights, the Tokuyama Groupsupports and adheres to international human rights norms, such as the UN International Bill of
Human Rights, the International Labor Organization Declaration on Fundamental Principles andRights at Work, and the UN Guiding Principles on Business and Human Rights. Moreover, as asignatory of the UN Global Compact, we also support and follow the Ten Principles of the UN GlobalCompact.
The Tokuyama Group recognizes that its business activities could potentially have adverse
impacts on the human rights of stakeholders, or contribute to such impacts, while its businesses,
products and services could have direct adverse impacts on human rights in the broader society.
Therefore, we strive to avoid any human rights infringement while addressing any adverse humanrights impacts that the Group’s activities may contribute to.

2. Scope
This Policy applies to all officers and employees of the Tokuyama Group. Moreover, we expect allbusiness partners and others who are directly involved in any Tokuyama Group business, product,or service to support and respect the Policy, and we encourage all to strive to protect human rights.

3. Respect for Human Rights
The Tokuyama Group is committed to avoid infringing upon the human rights of anyone affected byits business activities, and for this purpose, emphasizes the following six pledges.
1) Prohibition of discrimination
The Tokuyama Group promotes diversity and does not permit discrimination against anyone on
the basis of a personal attribute that is completely unrelated to the performance of duties. These
attributes may include birth, nationality, race, ethnicity, gender, age, occupation, employment type,educational background, religion, creed, sexual orientation, gender identity, marital status,
pregnancy, illness, disability, or economic background.
2) Prohibition of actions that can harm individual dignity
Under no circumstances will the Group engage in or condone activities that may violate the human rights
or dignity of individuals, such as engaging in physical violence, using abusive language, making
derogatory comments, slander, coercion, inhumane treatment, or harassment.
13) Prohibition of forced or child labor
The Tokuyama Group will never use forced or child labor for its business activities in any country orregion.

4) Respect basic labor rights
The Group recognizes basic labor rights, including freedom of association and the right to collective
bargaining, and strives to build and maintain cooperative labor-management relationships throughdialogue. Moreover, we comply with all relevant laws and regulations, while implementing responsible
labor practices, such as providing fair and appropriate wages and properly managing working hours.

5) Occupational safety and health
The Group seeks to build workplace environments that enable employees to work in safety and health.
We comply with the occupational safety laws and regulations of the countries and regions in which weoperate, and we strive to prevent work-related accidents and disasters.

6) Respect privacy
The Group will respect the privacy of individuals and will only collect personal information to theextent that is necessary and appropriate. All personal information collected will be handledappropriately in accordance with the relevant laws and regulations of each country concerned.

4. Efforts to address human rights issues
1) Education and awareness-raising
The Tokuyama Group will implement the appropriate education and awareness-raising activities toensure that all officers and employees have a proper understanding and awareness of human rights.

2) Human rights due diligence
Based on this Policy, the Group works to identify any adverse impacts on the protection of humanrights within the Tokuyama Group and at any business partner directly involved in a TokuyamaGroup business, product, or service. We build and continue to implement mechanisms to prevent,minimize, and rectify any such impacts, and to evaluate the effectiveness of our efforts. We also
explain and disclose information on how we are dealing with adverse impacts.
Moreover, if human rights are found to be adversely affected in the Group's supply chain, wewill urge the business partners concerned to rectify the situation.

3) Remedy and complaint mechanisms
Whenever it becomes clear that one of the Group’s business activities has caused or contributed2

to an adverse human rights impact, the Group will work to remedy the situation with appropriate
measures. Moreover, if it becomes clear that a Group business, product, or service is causing adirect adverse impact on human rights, we will take appropriate measures to prevent and mitigate
the impact concerned.
We strive to identify and rectify human rights issues at an early stage through proper operationof our whistleblower system and effective maintenance of reporting mechanisms. In addition, we
regularly review the whistleblower system to ensure remedies are effective.

4) Information disclosure
The Tokuyama Group regularly discloses its efforts to ensure respect for human rights, as well as
the results of such activities, on its website and elsewhere.
5) Applicable laws
The Group complies with all relevant laws and regulations in the countries and regions in which
it operates. Wherever internationally recognized human rights standards are not adequately
upheld by local laws and regulations, we pursue ways to comply with international standards to
the greatest extent possible.

On behalf of the Tokuyama Group, I hereby express the Group’s firm commitment to respectinghuman rights and complying with this Policy.
Hiroshi Yokota
Representative Director, President and Executive Officer
December 1, 2022

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