Sumitomo Corporation Group Anti-Corruption Policy

Preface
At Sumitomo Corporation, compliance is based on the Management Principles rooted in theSumitomo Business Philosophy of maintaining integrity and sound management and avoiding
the pursuit of easy gains, and on its Activity Guidelines that include the obligation “(t)o complywith laws and regulations while maintaining the highest ethical standards.” Compliance has thehighest priority in all corporate activities, and must never be sacrificed in the interest of profits.
Under the overriding principle of giving top priority to compliance at all times, we haveundertaken strict measures to prevent bribery, improper provision of benefits, and other forms ofcorruption. In 2009, we became a signatory to the “Ten Principles of the United Nations GlobalCompact,” which advocate for values common to our own Management Principles and which
include the principle of anti-corruption.
We have long internally made it known that, in keeping with the provisions and spirit of the law,
any provision of entertainment, gifts, or other such favors to the Japanese government or otherpublic officials is as a principle prohibited. Also, upon Japan’s revision of the Unfair
Competition Prevention Act in 1999, we launched an internal screening system for preventing
improper payments to foreign government or other public officials, to ensure theappropriateness of entertainment, gifts, and invitations given to such officials, as well as
payments to agents, consultants or other business intermediaries engaged to solicit businessfrom customers. In 2014, the screening system was expanded into our internal Rules forPrevention of Bribery to Foreign Public Officials. Thereafter, we have continued to modify theinternal rules and expand them to our business sites outside of Japan, as a way to takecomprehensive measures for preventing corruption in Japan and overseas.
Now, in response to the frequently asked questions and expectations of our stakeholders, wehereby establish and announce this Sumitomo Corporation Group Anti-Corruption Policy layingout our basic approach to anti-corruption.

Sumitomo Corporation Group Anti-Corruption Principles
The Sumitomo Corporation Group will not commit bribery or conduct any activity raising thesuspicion of bribing Japanese government or other public officials; and will as a principle
prohibit its officers and employees from providing such officials with entertainment, gifts or theequivalent. It will not make any offer, payment, promise to pay, or authorize the payment of any
money or anything of value to any foreign government or other public official, for the purposeof influencing any act or decision of such official in order to assist it in obtaining or retaining
business.

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In the event that anyone in the Sumitomo Corporation Group receives a request from a domestic
or foreign public official for such an act, we will reject the request and contact the relevant
authorities as the situation demands.
The Sumitomo Corporation Group will actively and sincerely engage in efforts to prevent
corruption through various internal control systems and ongoing initiatives.

Internal Control and Initiatives for Anti-Corruption
1. Internal System for Anti-Corruption
Sumitomo Corporation complies with the Japan’s Penal Code and Unfair Competition
Prevention Act, the U.S. Foreign Corrupt Practices Act of 1977, the UK Bribery Act 2010, andother domestic and foreign anti-bribery laws and regulations applicable to its business activities.
It establishes and administers the internal anti-corruption system described below to comply
with those laws and regulations and implement the Group Anti-Corruption Principles. In theevent that an officer or employee acts in violation of anti-bribery laws and regulations, it will
punish the violator under the relevant employment regulations.
(1) Internal Review(a) Review of entertainment, gifts, and invitations
We review these matters in advance by taking procedures as stipulated in our internalrules, taking into account the country of the government or other public officials, thevalue of the entertainment and gifts and other details, the timing and timeline of thematter and related events, the reason and purpose, the frequency, the standing of thegovernment officials, and other aspects, in order to avoid not only the violation ofapplicable laws but even the appearance of providing improper benefits to government orother public officials going beyond the appropriate social courtesies.
Small payments to government or other public officials for the purpose of facilitatingprocedures in ordinary administrative services (“facilitation payments”) are prohibited asbribery of officials in many countries. Sumitomo Corporation likewise has internal rules
prohibiting facilitation payments.
Even for entertainment and gifts between private companies or private citizens, weconfirm in advance that there are no improprieties under the applicable laws and social
norms in the country concerned.
(b) Review of donations
Regarding charities, political contributions, sponsorships, and other donations, wereview matters in advance by taking the procedures stipulated in our internal rules inorder to avoid bribery or provision of improper benefits.

2(c) Review of service providers
Regarding the appointment of agents, consultants, or other business intermediaries fromwhich Sumitomo Corporation requests cooperation in promoting its business overseas,such as gathering and analyzing information in marketing activities, or in obtaining
orders (“service providers”), Sumitomo Corporation prohibits its officers and employees
from instructing, suggesting, or assisting such service providers to commit bribery.
Additionally, to prevent bribery of public officials by service providers, we make efforts
to manage them by implementing internal procedures and contractual and other measures,as stipulated in our internal rules.
The head of an organization undertaking the above matters is required by our internal rules,
in order to self-assess and manage such matters properly, to obtain in advance various
information about the government officials or service providers including credit reports, toprepare the prescribed checklist and confirm that there is no issue for concern, and,especially in appointing service providers, to receive from each of them written agreements
or confirmatory documents incorporating anti-corruption provisions. If, as a result of theinternal review in the organization involved, there are found to be matters which needcaution, then the organization is required to have an additional review conducted by theresponsible administrative department and is allowed to carry out only the matter finallyapproved (if applicable, under the approval conditions).
(2) Record management and accounting
Our officers and employees are obligated to keep accurate books and records of the above
matters, to record expenses under the proper accounts, and to preserve the documents forthe period stipulated in the internal rules.
(3) Immediate internal reporting and whistleblower program
Our internal rules require our officers and employees to immediately report any acts of or
suspicion of corruption to the head of the Legal Department if and when they becomeaware of them. We also maintain and administer a whistleblower program so-called the“Speak-Up System” to enable our officers and employees to report compliance problems,
including corruption, directly to the Chief Compliance Officer, and to discover and correctsuch problems promptly, ensuring that they are also able to report and consult outside
attorneys and corporate auditors.
(4) Raising awarenessTo ensure awareness of anti-corruption and the internal control system for achieving it, we
maintain and administer our internal rules as described above as well as guidelines andmanuals, also taking into account worldwide trends of anti-bribery laws and enforcements,
prior cases in other companies, and advice from outside experts.
We also obtain written pledges for compliance including anti-corruption from our officers

3and employees, and conduct e-learning including case studies and practice and various
other in-house training geared to the nature of the business operations, on a repeated andongoing basis.
In addition to the above, by providing guidance for our officers and employees on specificmatters, we continue to make ongoing efforts to devise and administer effective and efficientmechanisms for anti-corruption.
Please also see the Sumitomo Corporation website on Compliance for details of the overall
compliance program.

2. Initiatives in investment activities and our domestic and overseas subsidiaries
When considering investments, the Sumitomo Corporation Group conducts risk-based due
diligence and obtains representations, covenants and other confirmations from parties toinvestment contracts, from the standpoint of anti-corruption.
Sumitomo Corporation also encourages its local offices and subsidiaries in Japan and overseas
to set up and maintain compliance and anti-corruption systems similar to those in the Sumitomo
Corporation headquarters, if appropriate from the perspective of corruption risk, and actively
work on anti-corruption on a group-wide basis.

3. Monitoring and internal audits
We review our anti-corruption programs from the perspective of whether they are adequatelyand efficiently provided and administered in line with the nature of the business operations, andmodify the programs and improve our administration as necessary.
The Internal Auditing Department, which reports directly to the President and CEO, wasestablished as an independent organization to monitor the operations of the Sumitomo
Corporation Group. The Internal Auditing Department reports all the internal audit results
directly to the President and CEO, and also regularly reports to the Board of Directors. It
comprehensively checks assets, risk management, and the status of compliance and businessprocesses to determine their problems and inherent anti-corruption risks, and also helps to raise
the quality of organizational management by encouraging voluntary improvements andevaluating the effectiveness and validity of each process.

4. Request to business partners for cooperation
Essential for thoroughgoing anti-corruption compliance, including this Anti-Corruption Policy,
are the understanding and cooperation not only of Sumitomo Corporation Group officers andemployees, but also of its business partners. Accordingly, we would appreciate our business4

partners’ understanding of this Anti-Corruption Policy and their cooperation regarding thefollowing matters.
(1) Cooperation with due diligence and investigations and written agreements
Particularly in transactions involving acquisitions, joint business including joint ventures,consortiums and other partnerships, and service transactions, business partners and theiraffiliates may be asked to undergo due diligence or investigation by the Sumitomo
Corporation Group to determine and confirm their internal systems for anti-corruption, toprovide written confirmation of their anti-corruption status and other related information,and to execute agreements including anti-corruption-related provisions. Your understanding
and cooperation are requested.
(2) Familiarization with anti-corruption
Business partners are requested also to institute training or other means to make sure that
their officers and employees, as well as third parties such as subcontractors, are familiar
with the applicable anti-bribery laws and the essentials of this Anti-Corruption Policy.
(3) Proper record management
In carrying out your business operations in relation to the Sumitomo Corporation Group,
you are asked to prepare and maintain accounting books and other records for alltransactions and disposition of assets accurately and in a timely manner.
(4) Cooperation with response to suspected violations
Should any corruption or accounting fraud or suspicion of the same arise in your business
operations in relation to the Sumitomo Corporation Group, you are asked to promptly
contact the Sumitomo Corporation Group and to give your full cooperation with audits orinvestigations whether by the Group or by the relevant authorities.

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