Basic Policy for Responsible Procurement of Minerals/Raw Materials
As a member of the Sumitomo Chemical Group and under the "Sumitomo ChemicalGroup Human Rights Policy", Tanaka Chemical Corporation defines those raw
materials in the supply chain that involve a high risk of having a negative impact onhuman rights as high-risk raw materials (“HRRM”). Tanaka Chemical Corporation
recognizes the adverse impact against human rights which may be associated withmining, extracting, refining, manufacturing, trading, handling and/or importing/exporting
HRRM, and we comply with the Sumitomo Chemical Group's Policy on Responsible
Procurement of Minerals/Raw Materials

Tanaka Chemical Corporation Approach to HRRM Issues
Incorporating the essence of the standards set out in the OECD Due Diligence
Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and HighRisk Areas (the “OECD Guidance”) with necessary adjustments, Tanaka ChemicalCorporation adopts the following 6-step framework in conducting due diligence inrespect of HRRM:
1. Establish Strong Company Management Systems
Tanaka Chemical Corporation shall clearly communicate and explain to suppliers
and to the public the contents of this policy, and appoint a executive and staff
assigned to supply chain management of HRRM. Tanaka Chemical Corporation shallconduct risk assessments of HRRM suppliers in accordance with international
standards such as RMI（Responsible Minerals Initiative）, and shall request HRRM
suppliers to comply with this policy by abiding by the contract clause or commitment
letter.
2. Identify and Assess Risks in the Supply Chain
Tanaka Chemical Corporation shall establish a system of controls and transparency
over the supply chain of HRRM, and will periodically identify and assess risks ofHRRM suppliers through an approach consistent with OECD Guidance Annex II.
In identifying and assessing the risks, Tanaka Chemical Corporation shall (i)request HRRM suppliers to map its supply chain to origin and maintain a database of
the same, and (ii) conduct additional due diligence procedures against the HRRM
supplier, when red-flags of adverse impact on human-rights are discovered in its

supply chain, with due attention to the geographical characteristics of conflictaffected and high-risk areas.
3. Design and Implement a Strategy to Respond to Identified Risks
Once risks are identified and mitigation measures are undertaken, the executive
assigned to HRRM, shall compile a risk management plan and shall implement
either of the following measures:i) continuing trade throughout the course of measurable risk mitigation efforts;ii) temporarily suspending trade while pursuing ongoing measurable risk mitigationefforts;iii) disengaging with the HRRM supplier after failed attempts at mitigation, such aswhere lack of cooperation, refusal to follow improvement requests etc.
Tanaka Chemical Corporation shall implement the risk management plan, monitorand trace the risks and progress of risk mitigation efforts, report them to the assigned
executive of HRRM, and keep record of the same for a designated period. Tanaka
Chemical Corporation shall undertake additional assessments of the identified risks
once there is change of circumstance.
4. Tanaka Chemical Corporation shall request HRRM suppliers who is in a position tomore directly and effectively mitigate the adverse impact on human rights in thesupply chain to undergo supply chain due diligence audits conducted by Tanaka
Chemical Corporation or by Tanaka Chemical Corporation’s designated independent
third-party auditor.
5. If required, Tanaka Chemical Corporation shall request HRRM suppliers to report its
HRRM related activities periodically to Tanaka Chemical Corporation, and topromptly report to Tanaka Chemical Corporation any signs of adverse impact onhuman-rights discovered in their supply chain, and to follow any instructions ofcorrective measures by Tanaka Chemical Corporation.
6. Tanaka Chemical Corporation shall support relevant industry initiatives in respect of
HRRM and respond to changing situations flexibly.
Effective October 1, 2021
Revision March 10, 2023
Executive Officer Satoru Nippa