Sumitomo Corporation
Slavery and Human Trafficking Statement for the Fiscal Year 2022

Sumitomo Corporation (SC) is committed to improving its practices to combat modern
slavery and human trafficking. This statement has been published in accordance with the
UK Modern Slavery Act 2015 and constitutes SC’s modern slavery and humantrafficking statement for the fiscal year 2022 ended March 31, 2023. This statement wasapproved by the board of directors of SC on July 18, 2023.

Background and organisational structure
SC is an integrated corporate committed to business activities in a wide range ofindustries with over 120 offices and subsidiaries in over 60 countries and a network ofover 850 group companies worldwide. With its global network and based on trust fromcompanies in various industries and from consumers, SC engages in multifacetedbusiness activities by making the most of its integrated corporate strength. Thesebusiness activities include sales of a variety of products and services within Japan,
import and export, trilateral trade, and domestic and international business investments.
SC employs over 5,000 people.
For more information on SC’s business overview, please visit the following link:
https://www.sumitomocorp.com/en/jp/about

Steps taken to ensure that modern slavery and human trafficking are not taking
place in SC’s business and supply chains
At the core of SC lies Sumitomo's Business Philosophy, which has been passed down
and followed faithfully for more than 400 years since Masatomo Sumitomo (1585-1652)
had founded. SC Group’s Corporate Mission Statement (Management Principles andActivity Guidelines) is based on this philosophy and represents our fundamental andultimate value standard. In the Corporate Mission Statement, it clearly states that we
respects the personality of each individual and places prime importance on integrity andsound management.
To enhance our sustainability management, we have identified our Six Key Social Issues
and the Long-term Goals in fiscal 2020. The six key social issues are related to ourbusiness that we address through our business and corporate activities and consist of twothemes: the sustainability of society and development and evolution of society. One of
the six key social issues is “respect for human rights,” and its long-term goal is “respect1human rights through all of our businesses and supply chains.” In the interest ofaccountability, our progress will be monitored and disclosed to its stakeholders.
We take its commitment to tackling modern slavery and human trafficking very seriously.
The followings are the steps which SC has taken to help ensure that modern slavery andhuman trafficking are not taking place in SC’s business or supply chains:
SC Group’s Human Rights Policy
We respect the International Bill of Human Rights and the International Labor
Organization (ILO)’s Declaration on Fundamental Principles and Rights at Work, andwe operate in accordance with the United Nations (UN) Guiding Principles on Businessand Human Rights.
In line with SC Group’s Human Rights Policy, i) we strive to identify and to prevent or
mitigate any adverse impact on human rights through the implementation of humanrights due diligence processes, ii) where we identify that our group’s practices havecaused or contributed to an adverse impact on human rights, we will endeavor to takeappropriate remedial measures, iii) we will seek to improve and progress human rights
measures through engagement and dialogue with relevant stakeholders, and so on.
In fiscal 2021, we have also established the Medium-term Goals for each Key Social
Issue by indicating specific action plans. With regards to “respect for human rights,” oneof our medium-term goals is “promote and ensure respect for human rights in accordancewith the UN Guiding Principles on Business and Human Rights and SC Group’s Human
Rights Policy.” In order to meet this goal, we have been strengthening risk analysis in
human rights due diligence in all businesses, including the supply chain, leading to
implementation of risk mitigation measures by 2025.
Also, we opened a consultation desk in our website to receive any opinions or requests
on sustainability-related issues such as human rights or environment from ourstakeholders. Any opinions or requests will be promptly shared internally throughCorporate Sustainability Department that specializes in addressing sustainability-related
issues, in addition to working with external experts as the situation requires, andnecessary actions will be taken to resolve issues. The content of inquiries is reported tothe management, including CSO, and the Corporate Sustainability Committee as
required. Furthermore, based on the results of assessments through human rights due
diligence and comments from our stakeholders etc., we are aiming to establish a more
effective grievance mechanism for our stakeholders.
Human Rights Due Diligence
In accordance with SC Group’s Human Rights Policy, we began human rights due
diligence in fiscal 2020 so that we can identify, prevent, mitigate and account for how
we address any adverse human rights impact that SC Group’s business activities may
cause or contribute to.
Our human rights due diligence is conducted through a process in accordance withinternational guidelines including the UN Guiding Principles on Business and Human
Rights, the UN Guiding Principles Reporting Framework, and OECD Due Diligence2

Guidance for Responsible Business Conduct. As a first step in fiscal 2020, we
identified eights salient human rights issues that should be addressed with priority sothat we can assess impacts concerning human rights throughout SC Group, by thedesktop survey, interviews of experts on business and human rights and internalinterviews.
Identified eight salient human rights issues are as follows；
Labor conditions (wages and working hours), Freedom of association and the right tocollective bargaining, Forced labor and child labor, Occupational health and safety,
Health and safety of local residents, Land rights, Discrimination and harassment, andPersonal information and privacy.
We believe that the human rights of workers throughout the supply chain including SC
Group’s employees are essential as the foundations of business. In addition to ‘ Freedomof association and collective bargaining rights’, ‘Forced labor and child labor’,‘Discrimination and harassment’ and ‘Occupational health and safety’, which are related
to the five core labor standards of the ILO, we also take action to address ‘Labor
conditions’. SC engages in business with strong ties in local communities centered on
the infrastructure business and resource development, and we have a responsibility toprotect ‘Health and safety of local residents’ and ‘Land rights’. Moreover, since SC
engages in wide-ranging business, we have positioned ‘Personal information and privacy’of stakeholders including customers as priority issues.
For each of these issues, we will carry out action plans to prevent and mitigate specificrisks with priority on areas of high risk in SC Group’s business.
We have started conducting human rights due diligence by business unit since fiscal
2021 aiming to our medium-term goal of “Strengthen risk analysis in human rights due
diligence to accurately assess risks in all businesses, including the supply chain andimplement risk mitigation measures by 2025.” In fiscal 2022, we have conducted
human rights due diligence on Infrastructure Business Unit and Mineral Resources,
Energy, Chemical & Electronics Business Unit, following Media & Digital Business
Unit and Living Related & Real Estate Business Unit in fiscal 2021. Specifically,
interviewing all related Strategic Business Units (SBUs) of four business units with thesupport from outside experts, we confirmed the situation in each business and actual
human rights risks including the impact on stakeholders, such as local residents andother related to the supply chain and business activities of each business. Besides, we
identified potential risks that could be anticipated and discussed the status of any
responses being taken. In light of these findings and from the perspectives of thepossibility to materialize human rights risks which we identified and their severity ifmaterialized, we identified SBUs or individual businesses within SBUs that should beprioritized for risk mitigation and considered and implemented measures to prevent or
mitigate the identified human rights risks. (For more information about the actual andpotential risks identified and assessed in the human rights due diligence by business
units and the assessment and countermeasures, please refer to the ESG Communication- Disclosure Book.)
We will identify and assess human rights risks in other business units as well andimplement measures to prevent or mitigate those human rights risks in each SBU.

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Through ongoing monitoring of each, we will also implement the plan-do-check-act(PDCA) cycle to identify new initiatives.
The SC Group CSR Action Guidelines for Supply Chain Management
We have established the SC Group CSR Action Guidelines for Supply Chain
Management. Through the implementation of these guidelines, we are aiming to realize
a sustainable society by working together with our suppliers, business partners andcontractors, etc. to achieve responsible value chain management. As part of theseguidelines, we set out its values to “Respect for human rights and not to be complicit inhuman rights abuses” and to “Prevent forced labor, child labor and the payment of
unfairly low wages.” These principles establish the overarching guidelines
encompassing our commitment to combating modern slavery and human trafficking.
In the event that we find violations of these guidelines in our supply chains, we will urge
the suppliers, business partners or contractors, etc. to remedy and improve the situation,
while providing support to them as needed. However, if there are no improvements tothe situation by them, we will consider carefully whether to continue our business withthem or not.
In fiscal 2021, we also established the SC Group Forest Management Policy and the SC
Group Sourcing Policy for Forest Products as specific policies for natural resourcerelated commodities requiring sustainable procurement. The policies include ourcommitment to respect human rights by operating forest related businesses in accordancewith SC Group’s Human Rights Policy as well as the UN Guiding Principles on Businessand Human Rights.
Group Governance
The management policy of SC Group is to respect "Jiritsu"* management by each groupcompany, and to be involved in important decision-making at the board of directors ororganization equivalent to the board of directors of each group company based on therelationship of trust established through active "Dialogue" as a shareholder, and to create
new value through strong "Collaboration" of each group company including SC.
With the aim of strengthening SC Group’s governance under the Medium-Term
Management Plan “SHIFT 2023,” in order to maximize our group’s corporate value
through sharing and putting into practice the principles of SC Group management, wehave established a Group Management Policy (GMP) that sets the three principles of SC
Group management: "Jiritsu", "Dialogue", and "Collaboration".
SC supports the establishment and operation of an optimal management system tocontrol risks appropriately and increase the odds of achieving its business strategies for
Jiritsu management of each group company.Specifically, we have introduced agovernance framework that uses SC Group standard tool called Basic Elements tovisualize the internal control status of each group company and solve issues identified
through “dialogue” with SC.
The Basic Elements include “Respect for Human Rights”, “Response to workplace
accidents”, “Labor Management, Health, Safety and the Environment”, and “Supplier

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Management”, and if there are issues, we formulate a response policy according to its
business nature and regional conditions. Through regular monitoring, we will continue
working to prevent modern slavery and human trafficking in SC Group’s business or
supply chains through further enhancing governance considering its business nature andregional conditions.
*"Jiritsu" is the Japanese term. In GMP, we define it to mean "following the rules
necessary for the management of each group company, such as SC Group’s management
principles, strategies, and policies, to discipline oneself, to think, make decisions, act for
oneself in order to achieve goals, and to be accountable to stakeholders".
Social and Environmental Risk Management in Individual Project
In order to promote social and environmental risk management for each business, taking
into account the nature of the business and the characteristics of the region where it
operates, we established a management system that considers social and environmental
impacts when making decision on a new investment, by utilizing an assessment sheet
for social and environmental risks, and by having the Corporate Sustainability
Department, a specialized organization for social and environmental issues, participate
in the process of deliberations.
After the implementation of each investment, we monitor the status of social andenvironmental risk management and if any issues arise, we will work for improvements
according to the characteristics of the business.
Active commitment to the UN Global Compact
We signed the UN Global Compact and declared its support for the 10 principles inMarch 2009. This international sustainability related initiative shares the same values as
our Corporate Mission Statement. With our participation in the Global Compact, wehave committed ourselves to further increasing corporate value by constantly seeking
out areas of our business activities that can be improved in light of the values advocatedby the 10 principles. The UN Global Compact has been referred also through the internal
auditing process of SC Group.
SC participates as a member company of the Global Compact Network Japan, a local
network of the UN Global Compact.
Training
In order to raise our awareness especially about modern slavery, we have utilized an
American NGO Verite's free e-Learning of Supply Chain Accountability on forced laborand human trafficking as a useful training material, which is one of the referred tools on‘Transparency in supply chains: a practical guide’ published by UK Home Office.
And also, we created our own e-Learning on business and human rights, and all of SC
executives and employees completed the training. In fiscal 2020, we added the same eLearning to the Global e-SBC training menu for overseas staffs and promoted learning.

5In fiscal 2022, SC conducted training for 101 new employees, 110 new chiefs, 119 new
managers, 82 new team leaders, and 25 new general managers on our sustainability
promotion, including respect for human rights.
Since SC conducts a wide range of business in multiple sectors, the associated risks vary,
however the eradication of any instances of modern slavery and human trafficking
remains a key priority.
We will continue to undertake these efforts aimed at ensuring that no modern slavery or
human trafficking of any form exists in our business and supply chains.
July 28, 2023

Signed by:
Hirokazu Higashino
Representative Director,
Senior Managing Executive Officer,
Chief Strategy Officer
Sumitomo Corporation

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