The Tokuyama Group Antimonopoly and Fair Competition Policy has been established underthe Tokuyama Group Code of Conduct, and all officers and employees of the Tokuyama Group
must comply with it.

Tokuyama Group Antimonopoly and Fair Competition Policy
Established April 1, 2023

1. Basic Stance
To ensure fair corporate activities, the Tokuyama Group engages in appropriate transactions
that are fair, are transparent, and support free competition.

2. Scope
This Antimonopoly and Fair Competition Policy applies to all officers and employees of theTokuyama Group. We also expect business partners of the Tokuyama Group to embrace thispolicy, and we encourage them to strive for fair, transparent, and free competition andappropriate transactions.

3. Organizational Structure
The Tokuyama Group maintains an effective organizational structure to prevent behavior that
could violate applicable antimonopoly and competition laws, and to enable effective incidentresponse.

4. Declaration of Compliance with Antimonopoly and Competition Laws
(1)

We faithfully comply with applicable antimonopoly and competition laws.

(2)

We take all necessary and appropriate measures to avoid violating antimonopoly andcompetition laws.

(3)

Whenever we become aware of information relating to a possible or actual violation ofantimonopoly and competition laws, we will respond promptly and appropriately.

(4)

We continually improve our internal controls for antimonopoly and competition lawcompliance.

(5)

We comply with applicable laws and regulations intended to prevent cartel behavior,
bid rigging, price fixing, abuse of superior bargaining position, etc., and we always
engage in appropriate transactions that are fair, are transparent, and support freecompetition.

(6)

We also comply with the Basic Purchasing Policy, which we have established to ensure
fairness and transparency in purchasing transactions, including contracting andconsignment.

(7)

When selecting business partners, we will consider not only economic rationality but
also the social responsibility efforts of prospective partners.

(8)

We comply with applicable laws and regulations concerning subcontracting.

(9)When conducting business with any level of government or a public institution, we doso fairly in accordance with the applicable bidding process and other established rules
and procedures.

5. Training and Awareness-Raising
The Tokuyama Group trains officers and employees to further improve their complianceawareness and prevent any activity that may violate antimonopoly and competition laws. The
aim is to ensure transactions that are fair, are transparent, and support free competition, andto ensure proper operation of relevant systems.

6. Intermediaries
The Tokuyama Group does not engage in transactions that could violate antimonopoly andcompetition laws using intermediaries.

7. Monitoring and Continuous Verification/Review
The Tokuyama Group regularly monitors the level of group companies and business partners
compliance with this Antimonopoly and Fair Competition Policy, verifies its effectiveness, andupdates it as necessary.

8. Incident Response
In the event that any business-related activity that may violate an antimonopoly orcompetition law is discovered and confirmed, the Tokuyama Group will take corrective action
and fully cooperate with investigations by the relevant authorities.