On the Establishment of the "SHI Group Anti-Bribery Basic Policy"

The SHI Group requires that its executives and employees maintain thorough compliance with laws,regulations, and corporate ethics, and to act at all times with a high degree of good sense. In recentyears, alongside increased global development of business, we have been making efforts to enhance
our international anti-bribery system, making it an important issue for the entire SHI Group.
At this time, we are clarifying the rules related to anti-bribery measures that our executives andemployees must comply with, formulating the Anti-Bribery Basic Policy with the goal of preventing
acts of bribery before they occur. This policy applies to every SHI Group company and all of their
executives and employees. Moving forward, we plan to continue our anti-bribery initiatives bydisseminating this policy and responding to the characteristics of and risks present in different
countries and regions.

July 1, 2021
President and CEO
Shinji Shimomura

SHI Group Anti-Bribery Basic Policy
Promulgated: July 1, 2021
Effective date: July 1, 2021

The SHI Group has established this Anti-Bribery Basic Policy to prevent bribery of public officials
and their equivalents (hereinafter, "Public Officials"), as well as private citizens and companies, bothin Japan and other countries, by SHI Group companies and their executives and employees. By
conforming to this policy, the SHI Group aims to prevent bribery and engage in fair competition andtransactions.
1. Compliance with laws
SHI Group companies, as well as their executives and employees, will comply with all of acountry’s laws related to anti-bribery.
2. Prohibition of bribery
SHI Group companies, as well as their executives and employees, will not engage in any acts ofbribery (including facilitation payments); and furthermore, will not pursue any goals that cannot
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be accomplished without the aid of acts of bribery. In the event that an SHI Group company, its
executive, or employee is requested to provide unlawful benefits to a Public Official or to a private
citizen or private company in any of the countries or regions in which the SHI Group conducts
business, the SHI Group company, executive, or employee will firmly reject the request andreport the incident as necessary to the appropriate authorities.
3. Prohibition of bribery via third parties
When an SHI Group company conducts business through a third party such as an agent orconsultant, or conducts business in partnership with a third party, the SHI Group company willapprove it after verifying that the standards provided in the SHI Group company's regulations
are met and that compensation is commensurate with the work performed. Further, the SHIGroup company will implement measures to prevent bribery through the third party, such as byincluding anti-bribery clauses in the contract with the third party.
In addition, payments made to third parties are prohibited from being used entirely or partiallyfor bribery, bribery-related acts, or acts that might constitute bribery. SHI Group companies andtheir executives and employees are prohibited from instructing third parties to commit acts ofbribery, as well as instigating or assisting any such acts.
4. Prohibition of excessive entertainment and gifts
If an SHI Group company or its executive or employee provides anyone with entertainment orgifts, they will comply with all relevant laws and company regulations. Any entertainment orgifts shall not be extravagant or excessive in light of socially acceptable norms.
5. Proper procedures and keeping of records
When appointing third parties such as an agent or consultant, or conducting business inpartnership with a third party, or providing entertainment and gifts, SHI Group companies will
properly conduct and appropriately keep the records of the inspection, approval, and decisionmaking procedures and accounting processes in accordance with company regulations.
6. Bribery prevention training
SHI Group companies will provide ongoing training to their executives and employees in order
to disseminate bribery prevention efforts.
7. Whistleblower system
SHI Group companies will implement and operate a whistleblower system to swiftly identify
bribery and take corrective action.
8. Monitoring and ongoing improvement
SHI Group companies will monitor their own compliance with this Anti-Bribery Basic Policy andother company regulations related to bribery prevention, as well as monitoring compliance by2/3

affiliated companies they control. Ongoing improvements will be implemented based on theresults of this monitoring.
9. Actions against offenders
In accordance with relevant company regulations such as employment regulations, SHI Group
companies will take strict action against any of their executives or employees who break the law
or company regulations related to bribery prevention. Other strict measures will also be taken
as required, such as reporting the offense to the relevant authorities and seeking damages fromthe offending executive or employee.

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