Sumitomo Corporation Group
Compliance Policy

Sumitomo Corporation Group’s
Corporate Mission Statement
Corporate Vision
We aim to be a global organization that constantly stays a step ahead in dealing withchange, creates new value, and contributes broadly to society.

Management Principles[Corporate Mission] To achieve prosperity and realize dreams through sound businessactivities[Management Style] To place prime importance on integrity and sound managementwith utmost respect for the individual[Corporate Culture] To foster a corporate culture full of vitality and conducive toinnovation

Activity Guidelines• To act with honesty and sincerity on the basis of Sumitomo’s business philosophy
and in keeping with the Management Principles• To comply with laws and regulations while maintaining the highest ethical standards• To set high value on transparency and openness• To attach great importance to protecting the global environment• To contribute to society as a good corporate citizen• To achieve teamwork and integrated corporate strength through active
communication• To set clear objectives and achieve them with enthusiasm

1

SC Group Compliance Policy

Part Ⅰ: Message from the President and CEO of Sumitomo

Corporation

page 3● What we need to do to achieve our dreams● What we cannot change

CONTENTS● The Sumitomo Corporation Group’s approach to achieve
Compliancepage 5

Part Ⅱ: About this Group Compliance Policy● Who does this Group Compliance Policy (or the “Policy”)
apply to?
● How does the Group Compliance Policy interact with the laws
or company rules?
● What are the employee’s responsibilities?
● What are the management’s responsibilities?
● How should I report a compliance issue?

page 7

Part Ⅲ: The Group Compliance Principles
1 Fair Competition
2 International Trade Regulations including Security Trade Control
3 Laws Relating To Your Business
4 Accuracy of Company Books and Records; Tax Compliance
5 Anti-Bribery and Anti-Corruption
6 Intellectual Property Rights
7 Information Management
8 Environmental Protection
9 Insider Trading
10 Respect for Human Rights and Prevention of Discriminationand Harassment

11 Conflicts of Interest

Part Ⅳ: About the “SC Global Speak-Up” System

page 13● What is the “SC Global Speak-Up” System?
● Who can use SC Global Speak-Up?
● What types of compliance issues can be reported through
SC Global Speak-Up?
● How does SC Global Speak-Up interact with any existing
internal whistleblowing systems or compliance hotlines?

SC Group Compliance Policy2

Dear all directors, officers and employees of the Sumitomo Corporation Group companies,

On my inauguration day as President and CEO of Sumitomo Corporation, I made an address to all 60,000 fellow colleagues,
including all directors, officers and employees working in any of the Sumitomo Corporation Group companies across theglobe, about the dreams and aspirations which I am determined to accomplish together.
■ Working hand-in-hand to enrich not only our employees’ lives, but also the broader society■ Striving to make our society more exciting through our business – the society to which the Fourth Industrial
Revolution is bringing major changes

In order to achieve these dreams and aspirations, I hope the Sumitomo Corporation Group will always be a group of people
who continue, simply and steadily, to use their best efforts.

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What we need to do to achieve our dreams

What we cannot change

We live in a time of major changes, that is, the Fourth
Industrial Revolution. As we strive to create newvalue and transform ourselves as is necessary tocontinue to grow in such changing times, we must
remember that our Corporate Mission Statement
based on Sumitomo’s Business Philosophy willcontinue to be our foundation.
The Sumitomo Corporation Group has always beenable to grow together with the changing times, but
the changes we are about to experience are expected
to be faster and greater than those of the past. While
the world and traditional values drastically change, weshall base our decisions on our values set forth in our
Corporate Mission Statement, and through soundbusiness activities, strive to achieve steady andsustainable growth in harmony with society.

Throughout Sumitomo’s history spanning over 400 years,

SC Group Compliance Policy

we can see the continuous efforts of our predecessors torealize our Corporate Mission Statement. Such unbroken
efforts have been passed on to us in the form of “信用(Shin-You)” – meaning “integrity” and “trust” – which is an
irreplaceable asset of our Group. In these changing times,
our customers and business partners will also be taking on
more challenges with greater uncertainty. What they canrely on under such situations is the trust that we are areliable partner with integrity. When we lose their trust, we
will lose their business. Without “信用 (Shin-You)”, or“integrity” and “trust”, the Sumitomo Corporation Group
cannot remain in existence.

The Sumitomo Corporation Group’s approach to achieve Compliance
When each of us performs our daily work in accordanceCompliance is a major prerequisite for any businesswith our Activity Guidelines that states, “To comply withactivity to be worthy of society’s trust. In order to maintainlaws and regulations while maintaining the highest ethicalthis trust, we must raise our sensitivity towards changes instandards”, we are protecting the trust that has beensociety’s values and maintain the highest ethical standards.

passed down through our long history, and this daily effort

When in doubt or under pressure, employees must reportis precisely the starting point of our compliance program.

to and consult with their managers without hesitation, andWe must continue to follow our principles of“Compliance as Top Priority”, which means that wemust never take part in any actions that are questionablefrom a compliance perspective , and “Immediate Report”,

managers must give their full attention to their teammembers. Use teamwork and communication to deal withsuch difficult situations.
The spirit of compliance of the Sumitomo Corporation

which means that, in the event of a compliance issue,

Group is something that has been passed down unbroken,

employees must report the situation without any delay toand which must be passed on to future generations.

their managers or the relevant persons or departments.

Compliance is not something that has been forced upon

There is one thing I would like for all of my colleagues to

us. Compliance is something that each and every one us

understand in relation to the principle of “Compliance as

sincerely puts into practice every day from our own will, as

Top Priority”. When we do business, there may be

we interact with our business partners, colleagues, andsituations in which the company’s profit and compliancesociety, while observing rules and ethics and maintaining

come into conflict. In such situations, we must neverintegrity.

violate compliance by giving priority to the pursuit of profit.

This “Sumitomo Corporation Group Compliance Policy”

The Sumitomo Corporation Group consists of companies

is a guide for all those who work in the Sumitomo

located across the globe and which are members ofCorporation Group companies. I ask my colleagues tovarious industries. However, what is common among all ofkeep this Policy in mind while performing their daily work,

us is that our businesses are based on society’s trust

so that we can realize the goals embodied in our

towards the Sumitomo Corporation Group, and we must

Corporate Mission Statement and accomplish our dreams

conduct business with integrity to meet the expectations oftogether.

society. The “Compliance as Top Priority” principle is an
essential part of our Corporate Mission Statement, and it isa code of conduct for each and all of us who work in the

March 2019

Sumitomo Corporation Group companies.
The principle of “Immediate Report” does not mean that
simply reporting a compliance issue is enough; rather, theaim of this principle is to ensure that compliance issues arereported to the management immediately, which will enable
us to gather the expertise of the relevant departments andpromptly resolve the situation in the best manner. It is
important that compliance violations, or situations whichsuggest the possibility of compliance violations, arereported immediately.

Masayuki Hyodo
Representative Director
President and Chief Executive Officer
Sumitomo Corporation

SC Group Compliance Policy

4About this Group Compliance Policy
Who does this Group Compliance Policy (or the “Policy”) apply to?
This Group Compliance Policy has been established to

Sumitomo Corporation Group. “Sumitomo Corporation

describe the Sumitomo Corporation Group’s approach toGroup” or “Group” shall mean, within this Policy, Sumitomo

compliance and provide guidance to all people working in

Corporation and its direct or indirect subsidiaries.

any of the Sumitomo Corporation Group offices across theSubsidiaries are any entities in which Sumitomo

globe. No matter where we are, this Policy should act as a

Corporation owns, directly or indirectly, more than 50

guide to assist our efforts to fully comply with thepercent of voting rights or which Sumitomo Corporation

applicable laws, rules and ethical standards at all times.

otherwise has the right to control. Any company within the

The Group Compliance Policy applies to all directors,

Sumitomo Corporation Group is a “Sumitomo Corporation

officers, employees, contract employees, part-time
employees, employees temporarily assigned to companies
outside of the Group and temporary employees

Group company”.
We are all required to understand this Policy and put it
into practice while performing our daily work.

(“Employees”) of any of the companies within the

How does the Group Compliance Policy interact with the laws or company rules?
Relationship between the Group Compliance Policy

Relationship between the Group Compliance Policy

Corporation Group company:

region:and the policies and rules of each Sumitomo

and the laws and regulations of each country orThis Group Compliance Policy explains the key principles

The Sumitomo Corporation Group does business acrossrelated to compliance which must be followed by all

the globe. Accordingly, our Employees must comply with

Employees across the Group. Employees should note thatthe laws and regulations of various countries and regions.

this Group Compliance Policy does not cover all of the● If a local law or regulation requires a higher standard

policies, rules or other standards which apply to eachthan this Group Compliance Policy, we must comply with

Employee. The policies and rules of each Sumitomo

such law or regulation.

Corporation Group company should be based on this● If the standard required by the local law or regulation isGroup Compliance Policy and provide greater detail tolower than the standard of this Group Compliance Policy,

take into account the local and industry-specific laws andwe must apply the standard of this Policy.

regulations.
The policies and rules of each Sumitomo Corporation
Group company must be consistent with the Group
Compliance Policy. If a Sumitomo Corporation Group
company has already established such policies and rules,
Employees of such company should continue to comply
with such company’s policies and rules.

What are the employee’s responsibilities?
All Sumitomo Corporation Group company employees are expected to perform the following responsibilities.
You must:

applicable to our business while maintaining the highest● Understand this Group Compliance Policy (or, if yourethical standards.

company already has an appropriate policy and/or rule,of a compliance issue, no matter how minor the issue.

practice while performing your daily work. When in(A further explanation on “Immediate Report” is provided

doubt about compliance while performing your work,

below.) You must also cooperate in good faith with any

refer to this Group Compliance Policy.

investigations or audits that the company or Group may● Comply with all laws, regulations and government orders

5● Make an “Immediate Report” when you become aware

understand such policy and/or rule) and put it into

SC Group Compliance Policy

conduct regarding the issue.

About this Group Compliance Policy
Who does this Group Compliance Policy (or the “Policy”) apply to?

What are the management’s responsibilities?

This Group Compliance Policy has been established to

Sumitomo Corporation Group. “Sumitomo Corporation

In addition to the employee’s responsibilities, the management of each Sumitomo Corporation Group company is expected todescribe the Sumitomo Corporation Group’s approach toGroup” or “Group” shall mean, within this Policy, Sumitomo

perform the following responsibilities.

compliance and provide guidance to all people working in

Corporation and its direct or indirect subsidiaries.

You must:

already has an appropriate policy and/or rule, make sure

any of the Sumitomo Corporation Group offices across theSubsidiaries are any entities in which Sumitomo● Frequently send clear messages to your company thatthey understand such policy and/or rule) and can apply it

globe. No matter where we are, this Policy should act as a

Corporation owns, directly or indirectly, more than 50

guide to assist our efforts to fully comply with thepercent of voting rights or which Sumitomo Corporation● Clearly demonstrate, both in action and words, thatapplicable laws, rules and ethical standards at all times.

otherwise has the right to control. Any company within thecompliance comes first. If your company is ever in a

The Group Compliance Policy applies to all directors,

Sumitomo Corporation Group is a “Sumitomo Corporation

situation where profit and compliance are in conflict, youissue reported to you through each “Immediate Report”.

Group company”.

must never leave the decision to be made by your staff

Do not neglect or make light of any compliance issue, noand you must take the necessary steps to ensure thatmatter how minor it may seem.

officers, employees, contract employees, part-time
employees, employees temporarily assigned to companies
outside of the Group and temporary employees

We are all required to understand this Policy and put it
into practice while performing our daily work.

(“Employees”) of any of the companies within thethe company’s first priority is compliance.

compliance is prioritized.
this Group Compliance Policy (or, if your company

Relationship between the Group Compliance Policy

Relationship between the Group Compliance Policy

Corporation Group company:

region:and the policies and rules of each Sumitomo

and the laws and regulations of each country or

achieve this.
● Properly respond to, and deal with, every compliance● Foster and maintain an ethically sound workplace● Make sure that your company’s Employees understandHow does the Group Compliance Policy interact with the laws or company rules?

in their work. Educate the Employees as necessary toenvironment characterized by effective communication
among all members of the company.

How should I report a compliance issue?
All Employees of the Sumitomo Corporation Group are

we will be better able to promptly respond and prevent therequired to make “Immediate Reports”. If you everissue from becoming more serious or wide-spread. This

This Group Compliance Policy explains the key principles

The Sumitomo Corporation Group does business across

become aware of an actual or suspected compliancewill also enable us to better protect the Group and its

related to compliance which must be followed by all

the globe. Accordingly, our Employees must comply withissue, you must report it immediately through your

Employees.

Employees across the Group. Employees should note thatthe laws and regulations of various countries and regions.

reporting line, which should usually be to your superior andthis Group Compliance Policy does not cover all of the● If a local law or regulation requires a higher standard

to any relevant department or persons in charge within

you must also immediately report to and consult with your

your company, as shown in the flowchart below.

superior and any relevant departments and ask for advice

policies, rules or other standards which apply to eachthan this Group Compliance Policy, we must comply with

Employee. The policies and rules of each Sumitomo

such law or regulation.

Corporation Group company should be based on this● If the standard required by the local law or regulation isGroup Compliance Policy and provide greater detail tolower than the standard of this Group Compliance Policy,

take into account the local and industry-specific laws andwe must apply the standard of this Policy.

regulations.

You do not need to wait to learn about the details of the

When you receive an Immediate Report as a manager,

or instructions to properly resolve the compliance issue.

issue to make a report. By making an Immediate Report,
The Flow of “Immediate Report” from a Sumitomo Corporation Group Company
Sumitomo Corporation

The policies and rules of each Sumitomo Corporation
Group company must be consistent with the Groupdifficult to report thecompliance issue along

Chief Compliance Officer andChief Executive Officer

Compliance Policy. If a Sumitomo Corporation Group

Legal Dept. and Relevant
Depts. of the Corporate Group

company has already established such policies and rules,
Employees of such company should continue to comply
with such company’s policies and rules.

If, for any reason, it isyour usual reporting line,
then you are encouraged
to use your company’s
whistleblowing system

Lead Organization or Partner Organization(if there is one) or the SC
Global Speak-Up System

What are the employee’s responsibilities?
All Sumitomo Corporation Group company employees are expected to perform the following responsibilities.
You must:

applicable to our business while maintaining the highest● Understand this Group Compliance Policy (or, if yourethical standards.

company already has an appropriate policy and/or rule,of a compliance issue, no matter how minor the issue.

practice while performing your daily work. When in(A further explanation on “Immediate Report” is provided

doubt about compliance while performing your work,

below.) You must also cooperate in good faith with any

refer to this Group Compliance Policy.

investigations or audits that the company or Group may● Comply with all laws, regulations and government orders

5● Make an “Immediate Report” when you become aware

understand such policy and/or rule) and put it into

SC Group Compliance Policy

conduct regarding the issue.

Sumitomo Corporation
Group Company

to report the issue. Please
see the final section of thisManagement
ManagerGroup Compliance Policy
Relevant Depts. or
Persons in Charge

for more details on the SC
Global Speak-Up System.

Employee* “Lead Organization” is the organization (usually a business unit) within Sumitomo Corporation or its regional offices that have a leadrole in supporting the particular Group Company. “Partner Organization” is the organization within Sumitomo Corporation or its
regional offices that have a supporting role with the same purpose.
* A Relevant Dept. may, for example, be your HR dept. if the compliance issue involves HR matters.

SC Group Compliance Policy

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The Group Compliance Principles

1
The Group Compliance Principles are composed of 11 key principles related to compliance which must be followed by all Employees
throughout the Group.
Below, you can find the 11 Group Compliance
Principles together with supplementary explanations of the Principles.
Please closely read the 11 Group Compliance
Principles and the supplementary explanations
to fully understand this Policy.

Fair
Competition
Principle:

We must promote fair competition through our businessactivities while always complying with the laws andregulations relating to anti-trust and fair competition.

Explanation of the Principle:●Anti-monopoly, Antitrust and Prohibition of
Anti-competitive Agreements
We must never create or take part in any impropermonopolies. We must also never enter into bid-rigging
agreements or other anti-competitive or collusive agreements with our competitors or abuse a dominant positionin the market. We may not engage in discussions withour competitors for the purpose of fixing prices or sales
volume, or allocating customers or sales territories and wemust avoid taking part in communications which may
create the appearance of such improper discussions. If a
competitor suggests that we enter into such anti-competitive arrangement, we must clearly and formally reject such
request. Such arrangements are never allowed withrespect to public or private tenders as well as day-to-daytransactions.

●Complying with All Applicable Laws
and Regulations

We must be aware that a collusive arrangement with acompetitor from a foreign country may lead to an “international cartel” issue. For example, if a collusive arrangement has an effect on the U.S. or EU markets, then even if
such arrangement is made in relation to a businessoutside the U.S. or EU, there is a possibility that the U.S.
Antitrust Laws or EU Competition Laws may apply.

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SC Group Compliance Policy

23International Trade
Regulations including
Security Trade Control

Laws Relating
to Your Business

Principle:

Principle:

as well as international treaties with respect to import andthe laws and regulations relating to our business.

We must comply with all applicable laws and regulations
export control, security trade control and customs.

Explanation of the Principle:

We must always study, fully understand and comply with

Explanation of the Principle:

As part of understanding our own business, we must

We must always follow internal rules with respect tostudy and understand all laws and regulations applicable

imports and exports of goods and technology so that weto our business, as well as be attentive to changes in thecomply with relevant laws and regulations as well aslaws or the creation of new, relevant laws, in order tointernational treaties with respect to import and export

make sure we are always compliant. Employees must

control, security trade control and customs. We must

understand that there are various laws and regulations

always understand the goods or technology being tradedconcerning each area of business. For example, there are

and confirm the identity of the purchaser, destination,

laws related to environmental protection, chemicals andend-user and end-use before making such trade. We

dangerous goods, and logistics. Whenever necessary,must also ensure that we have obtained all necessary

Employees should consult with the relevant departments

licenses and approvals from the relevant authorities. Weor persons in charge to learn about these laws andmust never engage in any business which may be or

regulations. Furthermore, we must never attempt to takewhich may have the appearance of being a threat toadvantage of any ambiguities or loopholes in the laws orinternational peace or security.

regulations.

SC Group Compliance Policy

8

The Group Compliance Principles

4

5

6

7

Accuracy of Company
Books and Records;
Tax Compliance

Anti-Bribery andAnti-Corruption

Intellectual
Property Rights

Information
Management

Principle:

Principle:

We must always stay committed to undertaking strict

Principle:

Principle:

We must maintain true and accurate books and records inmeasures to prevent bribery, improper provision of

the Sumitomo Corporation Group and we must also

the Sumitomo Corporation Group as well as the confiden-

a timely manner and properly retain all related documents.

benefits and other forms of corruption. We must neverrespect the IP rights of others.

tial information received from our business partners to

We must pay taxes and fulfill our tax reporting obligationscommit bribery or conduct any activity which may raisein compliance with the applicable laws and regulations

the suspicion of bribing a government or other public

and the Sumitomo Corporation Group Tax Principles.

official of any country, municipality or region. We must not

Explanation of the Principle:

offer, provide, or promise to provide cash or cash equivalents, gifts, entertainment or anything of value to public

We must protect the intellectual property (“IP”) rights of

Explanation of the Principle:●Protecting the IP Rights of the Sumitomo
Corporation Group

Copyrights, trademarks, patents and other forms of IP

We must properly manage the confidential information of

prevent any unauthorized disclosure or use of suchconfidential information.

Explanation of the Principle:●Managing the Confidential Information of
the Sumitomo Corporation GroupWe must maintain true and accurate books, records andofficials for the purpose of improperly obtaining orrights are valuable assets of the Sumitomo Corporation

related information in a timely manner to properly reflectretaining business. In the event that you receive a request

Group. If you become aware of a situation in which our IP

the company’s financial position and to protect thefrom a public official for such an act, you must reject therights are being infringed or there is a likelihood of suchconfidential information of the Sumitomo Corporationcompany’s assets. We must disclose necessary informa-

request and the company will contact the relevant

infringement, please report to and consult with yourGroup are valuable assets of the Group. We musttion in a proper and timely manner in accordance with theauthorities as the situation demands. We must comply

manager as well as the relevant departments or persons

properly manage such confidential information to prevent

laws and regulations in order to ensure the company’swith domestic and foreign laws and regulations concern-in charge.

leakage, loss, or unauthorized use.

transparency. The recorded documents and disclosed

ing anti-bribery and anti-corruption applicable to our

information must not include false or misleadingbusiness activities.

●Respecting the IP Rights of Others●Managing the Confidential Information of
Our Business Partners;
Prohibition of Improper Acquisition of Information

statements. Also, we must retain these documents andinformation in a proper manner and for the required lengthof time in accordance with applicable laws and regula-

Explanation of the Principle:

We must also pay careful attention to avoid any infringements of IP rights of others. For example, if you plan to

Trade secrets, know-how, personal data and otherFor the Sumitomo Corporation Group Anti-Corruption

produce or sell a new product which was developed with

tions.

Principles and further information on the internal control

new technologies, or if you plan to sell or promote ation received from our customers, suppliers and other

Please see below for the Sumitomo Corporation Groupsystems and initiatives of Sumitomo Corporation andproduct or service with a new logo or mark, you must firstbusiness partners in accordance with applicable laws andthose of its domestic and overseas subsidiaries for

conduct appropriate searches to ensure that others’ IP

regulations, our commitments to our business partners, as

anti-bribery and anti-corruption, please see the Sumitomorights are not infringed.

well as internal rules. Also, we must not acquire confiden-

Tax Principles:<Sumitomo Corporation Group Tax Principles>

Corporation Group Anti-Corruption Policy.

We must also properly manage any confidential informa-tial information of our competitors or others throughimproper means.

<Sumitomo Corporation Group Anti-Corruption Policy>●Properly Responding to Incidents

In the event of any incidents in which any confidential
information is misappropriated, lost, or improperly used,
we must respond immediately and take all necessary
measures to mitigate the impact of such incident on theowner of such confidential information.

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SC Group Compliance Policy

SC Group Compliance Policy

10

The Group Compliance Principles

67Intellectual
Property Rights

Information
Management

Principle:

Principle:

the Sumitomo Corporation Group and we must also

the Sumitomo Corporation Group as well as the confiden-

respect the IP rights of others.

tial information received from our business partners to

We must protect the intellectual property (“IP”) rights of

Explanation of the Principle:●Protecting the IP Rights of the Sumitomo
Corporation Group

Copyrights, trademarks, patents and other forms of IP
rights are valuable assets of the Sumitomo Corporation
Group. If you become aware of a situation in which our IP

We must properly manage the confidential information of

prevent any unauthorized disclosure or use of suchconfidential information.

Explanation of the Principle:●Managing the Confidential Information of
the Sumitomo Corporation Group

Trade secrets, know-how, personal data and otherrights are being infringed or there is a likelihood of suchconfidential information of the Sumitomo Corporation

infringement, please report to and consult with yourGroup are valuable assets of the Group. We must

manager as well as the relevant departments or persons

properly manage such confidential information to preventin charge.

leakage, loss, or unauthorized use.

●Respecting the IP Rights of Others●Managing the Confidential Information of
Our Business Partners;
Prohibition of Improper Acquisition of Information

We must also pay careful attention to avoid any infringements of IP rights of others. For example, if you plan toproduce or sell a new product which was developed withWe must also properly manage any confidential informa-

new technologies, or if you plan to sell or promote ation received from our customers, suppliers and otherproduct or service with a new logo or mark, you must firstbusiness partners in accordance with applicable laws andconduct appropriate searches to ensure that others’ IP

regulations, our commitments to our business partners, asrights are not infringed.

well as internal rules. Also, we must not acquire confidential information of our competitors or others throughimproper means.

●Properly Responding to Incidents

In the event of any incidents in which any confidential
information is misappropriated, lost, or improperly used,
we must respond immediately and take all necessary
measures to mitigate the impact of such incident on theowner of such confidential information.

SC Group Compliance Policy

10

The Group Compliance Principles

89

Environmental
Protection

Insider
Trading

Principle:

Principle:

We must comply with the Sumitomo Corporation GroupWe must not engage in any conduct which violates, orEnvironmental Policy and place great importance on

which may have the appearance of violating, the laws andprotecting the global environment, while striving to achieve

regulations on insider trading.

sustainable development through sound businessactivities.

Explanation of the Principle:

Explanation of the Principle:

Employees must not use material non-public information(“Insider Information”) of a company (whether or not such

10
Respect for Human Rights
and Prevention of Discrimination and Harassment
Principle:

11
Conflicts
of Interest
Principle:

We must always act in the best interest of the Sumitomo

We must respect the human rights of others and not

Corporation Group. We must never use company assets

tolerate any discrimination or harassment.

or our positions at our company to pursue our own or a

Explanation of the Principle:●Respect for Human Rights

third party’s interests at the expense of the Group’s
interests.

Explanation of the Principle:

We must comply with the Sumitomo Corporation Group

company belongs to the Sumitomo Corporation Group) to

Environmental Policy, all applicable environmental laws

purchase, sell, or cause others to purchase or sell,

prime importance on integrity and sound management

and regulations, and also abide by any agreements

publicly traded securities (such as stocks). Insider

with utmost respect for the individual” in its Management

concerning environmental protection. Please see below

Information generally means information which a reason-

Principles. This means that the Sumitomo Corporationmust act at all times in the Group’s best interests. You

for the Sumitomo Corporation Group Environmental

able investor would consider important in making aGroup respects the human rights of all individuals,

must not use your position or role at your company for

Policy:decision to buy, sell or hold a security, or which have a

including the rights of those with whom the Sumitomo

your own personal benefits.

significant effect on the market price of the security. For

Corporation Group has a relationship or contact.

< Sumitomo Corporation Group Environmental Policy>

The Sumitomo Corporation Group has pledged “to place

example, Insider Information includes information aboutplans of large-scale mergers or acquisitions or significant●Prevention of Discrimination and Harassment●Conflict of Interest

Each Employee has a duty of loyalty to the Group and●Activities Unrelated to Your Work

You must refrain from engaging in personal affairs or

We must not discriminate against any individual based on

activities which may interfere with your work responsibili-

event you become aware of any Insider Information, yourace, ethnicity, nationality, origin, color of skin, age, sex,

ties. If you are or plan to be involved in a commercial

must follow your Company’s internal rules and keep it

sexual orientation, gender identity, disability, religion,

activity which conflicts with the Sumitomo Corporation

confidential.

political affiliation, union membership, marital status, orGroup’s interests, you must promptly report this to yourAlso, you must comply with the applicable laws andany other grounds unrelated to our work. We must nevermanager.

regulations concerning insider trading of your own country

tolerate discriminatory speech or actions, harassment,or region, as the rules may be different in each country or

bullying, slander, libel, threats, violence or other unaccept-

region.

able behavior that instills fear in others, or would other-modifications of corporate earnings forecasts. In thewise make them uncomfortable.

●Proper Use of Company’s Assets and
IT Systems

You may only use your company’s assets including its IT
devices or IT systems for the purpose of performing yourwork and you must not use such assets for personal
purposes.

11

SC Group Compliance Policy

SC Group Compliance Policy

12

The Group Compliance Principles

10
Respect for Human Rights
and Prevention of Discrimination and Harassment
Principle:

11
Conflicts
of Interest
Principle:

We must always act in the best interest of the Sumitomo

We must respect the human rights of others and not

Corporation Group. We must never use company assets

tolerate any discrimination or harassment.

or our positions at our company to pursue our own or a

Explanation of the Principle:●Respect for Human Rights

The Sumitomo Corporation Group has pledged “to placeprime importance on integrity and sound managementwith utmost respect for the individual” in its Management

third party’s interests at the expense of the Group’s
interests.

Explanation of the Principle:●Conflict of Interest

Each Employee has a duty of loyalty to the Group andPrinciples. This means that the Sumitomo Corporationmust act at all times in the Group’s best interests. You

Group respects the human rights of all individuals,

must not use your position or role at your company forincluding the rights of those with whom the Sumitomo

your own personal benefits.

Corporation Group has a relationship or contact.

●Prevention of Discrimination and Harassment●Activities Unrelated to Your Work

You must refrain from engaging in personal affairs or

We must not discriminate against any individual based on

activities which may interfere with your work responsibili-

race, ethnicity, nationality, origin, color of skin, age, sex,

ties. If you are or plan to be involved in a commercial

sexual orientation, gender identity, disability, religion,

activity which conflicts with the Sumitomo Corporation

political affiliation, union membership, marital status, orGroup’s interests, you must promptly report this to yourany other grounds unrelated to our work. We must nevermanager.

tolerate discriminatory speech or actions, harassment,
bullying, slander, libel, threats, violence or other unacceptable behavior that instills fear in others, or would otherwise make them uncomfortable.

●Proper Use of Company’s Assets and
IT Systems

You may only use your company’s assets including its IT
devices or IT systems for the purpose of performing yourwork and you must not use such assets for personal
purposes.

SC Group Compliance Policy

12

“SC Global Speak-Up” System
What is the “SC Global Speak-Up” System?
“SC Global Speak-Up” is the name of the internal
whistleblowing system of the Sumitomo
Corporation Group. If you become aware of acompliance issue and believe (for any reason) it isdifficult for you to report the issue along your usual
reporting line, you may report the issue using yourcompany’s internal whistleblowing system (if there

Confidentiality

is one) or by using SC Global Speak-Up. Any
reports made through SC Global Speak-Up will be
communicated to the Chief Compliance Officer(“CCO”) of Sumitomo Corporation. When a report
is received, an investigation will be immediately
initiated. Sumitomo Corporation promises that thefollowing points will be most strictly observed:

No Retaliation

If an Employee reports a compliance issue through SC

Sumitomo Corporation is committed to prevent any

as the details of the report (including any facts or details

the report.

Global Speak-Up, the identity of the Employee as well

discovered through the investigation) will be held in thereprisals or retaliations against the Employee for making

strictest confidence.

Further details on SC Global Speak-Up are explained in “The SC Global Speak-Up Guidelines”.

13

SC Group Compliance Policy

SC Global Speak-Up“SC Global Speak-Up” System
What is the “SC Global Speak-Up” System?
“SC Global Speak-Up” is the name of the internal
whistleblowing system of the Sumitomo
Corporation Group. If you become aware of acompliance issue and believe (for any reason) it isdifficult for you to report the issue along your usual
reporting line, you may report the issue using yourcompany’s internal whistleblowing system (if there

Confidentiality
If an Employee reports a compliance issue through SC
Global Speak-Up, the identity of the Employee as wellas the details of the report (including any facts or details
discovered through the investigation) will be held in theis one) or by using SC Global Speak-Up. Any
reports made through SC Global Speak-Up will be
communicated to the Chief Compliance Officer(“CCO”) of Sumitomo Corporation. When a report
is received, an investigation will be immediately
initiated. Sumitomo Corporation promises that thefollowing points will be most strictly observed:

employees, contract employees, part-time employees,

employees temporarily assigned to companies outside

Sumitomo Corporation established SC Global Speak-Up

compliance issue through SC Global Speak-Up.

Sumitomo Corporation Group may use. If a Sumitomo

What types of complianceissues can be reported through
SC Global Speak-Up?

whistleblowing system or compliance hotline in place,

Sumitomo Corporation is committed to prevent any

Employees are encouraged to use SC Global Speak-Up

his/her company’s whistleblowing system or SC Global

the report.

have a large negative impact on the Sumitomo

No Retaliation
reprisals or retaliations against the Employee for making

Further details on SC Global Speak-Up are explained in “The SC Global Speak-Up Guidelines”.

SC Group Compliance Policy

All Employees (which include directors, officers,

How does SC Global Speak-Up
interact with any existing
internal whistleblowing systems
or compliance hotlines?

of the Group and temporary employees) of any

strictest confidence.

13

Who can use
SC Global Speak-Up?

Sumitomo Corporation Group company can report a

as a whistleblowing system that any company within the
Corporation Group company already has a similar

SC Global Speak-Up is an additional system for suchcompany, as Sumitomo Corporation does not intend to
replace or abolish any existing systems. An Employee
at a Sumitomo Corporation Group company may use

to report significant compliance issues which could

Speak-Up to report a compliance issue.

Corporation Group. For further details of the types of

Global Speak-Up, we will be better able to identify

Global Speak-Up, please see “The SC Global Speak-Up

resolve the issues at an early stage.

compliance issues that can be reported through SC

By introducing an additional way to report, that is SC

compliance issues, mitigate the negative effects andGuidelines.”

SC Group Compliance Policy

14

www.sumitomocorp.com

Published by: Sumitomo Corporation Legal Compliance Department

Sumitomo Corporation Group
Compliance Policy