Anti-Bribery and Corruption Policy

Date of Enactment: July 1st, 2024

1. Introduction
As a company engaged in business transactions domestically and internationally, Sekisui House, Ltd.
(“the Company”) and its group of companies in and outside of Japan (collectively, “we” or “theGroup”) pledge to pursue transparency and fairness, and will thoroughly comply with laws andregulations and corporate ethics.
The Company has set forth its basic approach in “Corporate Ethics Guidelines,” and with this AntiBribery and Corruption Policy (“the Policy”), it has formulated and declared a more specific behaviorpolicy for the Group’s efforts to comprehensively prevent all acts of bribery and corruption.
2. Scope of Policy Application
The Policy applies to all directors, officers, and employees of the Group, including part-time andcontract employees. Furthermore, we ask for the understanding and cooperation of all business partners
as well.
3. Adherence to Laws and Regulations
The Group will strictly comply with all laws, regulations, and guidelines of government agencies
regarding the matters set forth in the Policy. In the case that some countries have stricter regulations
than the Policy, or content not defined in the Policy, we will comply with the regulations of the relevant
countries in addition to the Policy.
4. Prohibition of Bribery, Etc.
The Group prohibits bribery and facilitation payments in any form to public officials or theirequivalents (collectively, “Public Officials, etc.”), whether in or outside of Japan.
* A public official refers to all directors, officers, or employees of a public institution and public internationalorganization, a legislator, or a candidate for public office. In addition, those who are equivalent to publicemployees include those who work for government-affiliated institutions and government-affiliated companies.
It is necessary to note that persons who are subject to bribery regulations as persons equivalent to public officials
vary from country to country. Furthermore, bribery of foreign public officials is also prohibited by the laws ofeach country, as well as Japan’s Unfair Competition Prevention Act.
* Bribery is the offering of something of value or benefit to a public official or other person with the intent toinfluence his or her official acts in order to obtain or maintain favors or other improper business advantages.
Bribery may take the form of any benefit, such as cash, gifts, provision of services, travel, entertainment,donations, loans, preferential treatment, discounts, etc., and may be executed even if the offer or promise of sucha benefit is made but the purpose is not actually achieved. In addition, the Group may be held legally liable forbribery not only when it is done directly by the Group, but also when it is done through a third party, such as abusiness partner.
* A facilitation payment is a payment made in a small amount to facilitate and expedite non-discretionary androutine administrative services such as the granting of a visa, customs clearance, and license issuance.

(1) Prohibition of entertainment, gift-giving, or other provision of benefits to Public Officials, etc.
for improper purposes
In principle, the Group prohibits the paying of expenses such as travel and meal expenses, provisionof entertainment, preferential treatment, gifts, and all other provision of benefits in connection withthe duties of Public Officials, etc. for improper purposes. The same applies to entertainment, gifts, andbenefits provided to friends, family, and other close relatives of Public Officials, etc.
* Exceptions are permitted for payments in emergency situations, such as when it is necessary to avoid danger tophysical liberty or life. However, it is required to promptly report such facts and circumstances and receive
approval from the responsible person, the relevant business administrative department, and the Company’s
Legal Department.

(2) Selection procedures for business partners
When the Group engages a business partner, whether as an agent, consultant, sponsor, intermediary,agency, or any other designation, to perform the Group’s business, we will sufficiently investigate toensure that, firstly, the Group’s actions do not constitute bribery, and that also bribery by the business
partner will not occur. In line with this, we will select an appropriate business partner, having obtained
the approval of the responsible person or the relevant business administrative department.
5. Appropriate Relationships with Business Partners, Etc.
We maintain fair, sound, and transparent relationships with our customers, suppliers, joint venture
parties, agents and brokers, and other business partners.
(1) Prohibition of conflicts of interest that arise by not following the prescribed internal procedures
In principle, the Group prohibits the conflicts of interest described below and will tolerate them only
in cases where the prescribed internal procedures are followed.
1)
A director, officer, or employee of the Group is employed by, or works as a consultant, or as
an individual for a business partner or other party.
2)
A director, officer, or employee of the Group conducts business with a company that ismanaged by either themselves or a family member, friend, or other close relative.
3)
Any attempt by a director, officer, or employee of the Group to take advantage of the Group’sproperty, information, or position for personal gain.
4)
Employment of family members, friends, and other close relatives of the Group’s directors,officers, and employees, and other business partners.
(2) Entertainment and gift-giving within the scope of general social common sense
In the event of entertaining, giving gifts, or any other form of beneficial treatment to customers orbusiness partners that do not fall under the category of Public Officials, etc., or when directors, officers,

or employees of the Group directly or indirectly receive entertainment, gifts, or any other benefits frombusiness partners, etc., they must carefully consider whether the purpose, necessity, degree, etc. ofsuch entertainment or gifts are within the scope of general social common sense and report to theresponsible person or the relevant business administrative department for approval.
6. Making Donations
The Group may make donations of money or goods to charitable organizations only after obtaining
prior approval in accordance with the prescribed internal procedures and in compliance with applicablelaws and regulations.
In addition, the Group will take care to ensure that donations do not pass through such organizations
to Public Officials, etc., by, for example, confirming that the directors/officers of the organization towhich the donation is made and their relatives are not Public Officials, etc., involved in the Group’sprojects.
7. Political Contributions
The Group will make political contributions only after obtaining prior approval in accordance withthe prescribed internal procedures and in compliance with applicable laws and regulations.
8. Accounting and Record Keeping
The Group shall make accurate accounting records for all transactions and disposal of assets andkeep them together with relevant materials.
9. Internal Training and Communication
The Group will ensure that all directors, officers, and employees are fully aware of and familiar withrelevant laws and regulations, the Policy, and separately established guidelines through periodic
internal training.
If there is any doubt regarding the interpretation or application of the Policy, the Group encourages
you to consult with the person to whom you report, your relevant business administrative department,or the Company’s Legal Department.
10. System of Management Supervision
The Risk Management Committee, an advisory body to the Company’s Board of Directors, manages
and supervises compliance with the Policy, and reports and responds to the Board of Directors asnecessary.
11. Detection of Violations through Utilization of the Whistleblowing System, Etc.
The Group will strive for the early and comprehensive detection of any violations of the Policy.
Employees may use the whistleblower system (Compliance Helpline, Global Helpline), which can beused anonymously and provides an alternative to normal reporting lines, if they become aware of orsuspect that a violation is taking place. Under the whistleblower system, the confidentiality of persons
who report violations or cooperate in investigations is protected, and any retaliation or otherdisadvantageous treatment of those who report or cooperate is prohibited.
12. Response to Violations and Investigations
The Group will investigate and confirm violations of the Policy, including with the establishment of athird-party committee if necessary, and will deal with such violations in a strict manner.
Moreover, in the event of receiving a request to cooperate with an investigation by relevant authorities,
the Group will fully cooperate with such investigations.
13. Responsible Department, Revisions, and Abolition Procedures
The department responsible for the Policy is the Legal Department of the Company. It will periodicallyreview, and if necessary, revise or abolish in line with prescribed internal procedures.