Sumitomo Corporation
Slavery and Human Trafficking Statement for the Fiscal Year 2023

Sumitomo Corporation (SC) is committed to improving its practices to prevent modern
slavery including forced labour, child labour and human trafficking. This statement
addresses the fiscal year 2023 (from April 1 to March 31, 2024), in compliance with therequirements of Modern Slavery Act 2015 of the UK. This statement was approved by
the board of directors of SC on July 23, 2024.

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 ofaround 900 group companies worldwide. With its global network and based on trustfrom companies 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 including forced labour, child labourand 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
respect the personality of each individual and places prime importance on integrity andsound management. Our corporate message “Enriching lives and the world” represents
our pledge to further enrich the world, society, and people's lives through sound businessactivities.
Furthermore, in order to achieve sustainable growth for SC Group through resolvingsocial issues, we formulated our "Material Issues" in 2017 and set "Key Social Issues"and each goal for working on our business activities in 2020. In 2024, we conducted areview of the "Material Issues" and "Key Social Issues" and integrated them into an
updated “Material Issues”. "Material Issues" are medium- to long- term commitment for
SC Group to take one step further toward addressing key social challenges that we must1

undertake. SC Group will achieve sustainable growth through addressing the social
challenges. We have set "Respect human rights" as one aspect of "Material Issues". We
will continue to promote these efforts and disclose our progress.
We take its commitment to tackling modern slavery including forced labour, child labourand human trafficking very seriously. The followings are the steps which SC has taken
to help ensure that modern slavery including forced labour, child labour and humantrafficking 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 Labour
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.
With regards to “Respect human rights” which is one of our Material Issues, one of our
medium-term goals is “promote and ensure respect for human rights in accordance with
the UN Guiding Principles on Business and Human Rights and SC Group’s Human
Rights Policy.”
Also, in addition to an internal whistleblower system for employees, we have set up acontact point on our website to accept opinions from external stakeholders. Specifically,
we have become a regular member of the Japan Center for Engagement and Remedy on
Business and Human Rights (JaCER), a general incorporated association that provides aplatform for redress of grievances in compliance with the UN Guiding Principles on
Business and Human Rights, and we accept various opinions on human rights from ourexternal stakeholders on the platform provided by JaCER. We accept opinions througha third party with expertise to improve fairness and transparency. Besides, the content ofgrievance is reported to the management, including Chief Sustainability, DE&I Officer
and the Corporate Sustainability Committee, to ensure that issues are corrected andprevented from recurrence in a timely and appropriate manner. In dealing with the report,
we ensure that the whistleblower and related parties will not suffer any disadvantages asa result of reporting, and we protect the privacy and confidentiality of the whistleblower.
The progress and results of the response to the received report will be disclosed on the
Grievance List on the JaCER website.
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

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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 labour, child labour and the payment of
unfairly low wages.” These principles establish the overarching guidelines
encompassing our commitment to preventing modern slavery including forced labour,child labour 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.
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 Diligence
Guidance for Responsible Business Conduct. As a first step in fiscal 2020, we
identified eight 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.
The identified eight salient human rights issues are as follows；
Labour conditions (wages and working hours), Freedom of association and the right tocollective bargaining, Forced labour and child labour, 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 labour and child labour’,‘Discrimination and harassment’ and ‘Occupational health and safety’, which are related
to the five core labour standards of the ILO, we also take action to address ‘Labour
conditions’. SC engages in business with strong ties in local communities centered on3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 a priority issue.
We started conducting human rights due diligence by business unit since fiscal 2021.
In fiscal 2023, we conducted human rights due diligence on Metal Products Business
Unit* and Transportation & Construction Systems Business Unit, following Media &Digital Business Unit and Living Related & Real Estate Business Unit in fiscal 2021
and Infrastructure Business Unit and Mineral Resources, Energy, Chemical &Electronics Business Unit in fiscal 2022**. Specifically, interviewing all related
Strategic Business Units (SBUs) of each business units with the support from outside
experts, we confirmed the situation in each business and actual human rights risks
including the impact on stakeholders, such as local residents and other 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.
We have not identified any forced labour or child labour in our activities and supply
chains.
In light of these findings and from the perspectives of the possibility to materialize
human rights risks which we identified and their severity if materialized, we identified
SBUs or individual businesses within SBUs that should be prioritized for risk
mitigation and considered and implemented measures to prevent or mitigate theidentified human rights risks. (For more information about the actual and potential
risks identified and assessed in the human rights due diligence by business units andthe assessment and countermeasures, please refer to the Sustainability Site ‘Implementation and Progress of Human Rights Due Diligence’.)We will continue to identify and assess human right risks, and implement measures toprevent or mitigate those human rights risks in each SBU. Through ongoing
monitoring of each, we will also implement the plan-do-check-act (PDCA) cycle toidentify new initiatives.
*Please note that although a significant organizational change was implemented as ofApril 1, 2024, the old organizational name is used in this statement to describe theresults for FY2023.
**In the first half of the fiscal 2024, human rights due diligence was conducted on
Energy Innovation Initiative, which completed the due diligence process across all
business units.
Group Governance
We have established a Group Management Policy (GMP) that is to respect "Jiritsu"*
management by each group company, and to be involved in important decision-making
at the board of directors or organization equivalent to the board of directors of each groupcompany based on the relationship of trust established through active "Dialogue" as ashareholder, and to create new value through strong "Collaboration" of each groupcompany including SC.

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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”, “Labour Management, Health, Safety and the Environment”, and “SupplierManagement”, 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 including forced labour, child labour and humantrafficking in SC Group’s business or supply chains through further enhancing
governance considering its business nature and regional conditions.
In addition, based on the concept of Jiritsu management, each group company to which theModern Slavery Act 2015 of the UK applies prepares and publishes its own statement. SC
provides necessary support to the group companies in complying with the law, including
making decisions on the application of the law and preparing statements.

*"Jiritsu" is a 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 including human rights issues when making decision on a new investment, byutilizing an assessment sheet for social and environmental risks, and by having the
Corporate Sustainability Department, a specialized organization for social andenvironmental 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.

5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 including forced labour,child labour and human trafficking, we have utilized an American NGO Verite's free eLearning of Supply Chain Accountability on forced labour and human trafficking as a
useful training material, which is one of the referred tools on ‘Transparency in supply
chains: a practical guide’ published by the 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.
In fiscal 2023, SC conducted training for 97 new employees, 197 new chiefs, 133 newmanagers, 118 new team leaders, and 41 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 including forced labour,child labour and human trafficking remains a key priority.
We will continue to undertake these efforts aimed at ensuring that no modern slavery
including forced labour, child labour or human trafficking of any form exists in ourbusiness and supply chains.

August 22, 2024

Signed by:
Takayuki Seishima
Representative Director,
Executive Vice President,
Sumitomo Corporation

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