Sustainability Report 2023

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Greetings from Atsumi & Sakai’s Representative
Dear All,
All at Atsumi & Sakai, a Foreign Law Joint Enterprise (the "Firm"), considers it one of our most important social missions
to contribute to the promotion of sustainability in both Japan and the international community by making full use of theexperience and knowledge that we have accumulated as a law firm.
Our Firm's philosophy is to "continue to honor innovative and cutting-edge creativity and take on new challenges","respect diversity, try to be inventive and flexible", and "bring the best of individual capability and the strength of teamwork". Based on this philosophy, in January 2023, the Firm established a Sustainability Committee (the "Committee") topromptly address various contemporary issues, including the growing importance of respect for human rights in theinternational community, addressing the petrochemical gas issue, responding to natural disasters and environmental
destruction caused by climate change and extreme weather, and promoting diversity and inclusion. In February of thesame year, the Firm’s "Sustainability Declaration" was released. We are pleased to inform you that the Committee has
now prepared its first Annual Sustainability Report.
The Committee, comprised of attorneys, registered foreign lawyers, and staff members boasting diverse experience, iscommitted to promoting sustainability by identifying key issues and policies, taking into consideration the contribution
and impact on the firm's stakeholders, including clients, the environment, and society. Our Firm has established asystem in which anyone can submit proposals for various sustainability-related projects to the Committee. Upon
validation, the Committee is responsible for supporting the implementation of such proposals, thereby maximizing
teamwork at the Firm together with recognizing the abilities of individuals with innovative ideas.
We will continue to contribute to the realization of a more sustainable society for all by making the most of ourknowledge as a law firm to address the issues and needs of society, including sustainability. We appreciate yourunderstanding and unwavering support.
Atsumi & Sakai
Managing Partner
Hiroo Atsumi, Attorney© Atsumi & Sakai 2024

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Message from the Chief Sustainability Officer
Dear All,
Thank you for your interest in A&S' commitment towards our sustainability efforts. As Chief Sustainability Officer, I am
pleased to present the first Annual Sustainability Report since the establishment of our Firm's Sustainability Committee.
As a law firm, our commitment to ethics, human rights, environmental protection, and social responsibility is an
unspoken obligation. In today's ever more demanding environment for sustainability, our Firm recognizes the importantrole that law firms play in driving positive change. We are focused on using our knowledge, insight, and influence as aprofessional group of attorneys to not only solve the challenges before us, but to shape a more sustainable future.
This report summarizes our Firm's specific sustainability efforts, achievements, and challenges in 2023 anddemonstrates our firm commitment to sustainability across all aspects of our activities. Through the indirectcontributions we make through the cases taken on for our clients, as well as participation in external organizations, pro
bono activities, information released through newsletters and seminars, the promotion of diversity within the office andconsideration for the environment, our Firm has been consistently advancing sustainability from within the organization.
This is achieved through regular discussions in Committees which help to better incorporate sustainability into ourpractices.
In 2023, we were fortunate and that these initiatives gained external recognition. In a rapidly changing internationalsociety, our Firm is committed to making continuous improvements and innovations. However, achieving truesustainability requires commitment from society as a whole. We believe that through ongoing interactive relationships
with our clients and stakeholders, whether through transactions, projects, or various external activities, together, ourFirm can achieve the common goal of building a sustainable future.
Yuri Suzuki
Chief Sustainability Officer© Atsumi & Sakai 2024

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Sustainability Declaration
Sustainability Initiatives
Atsumi & Sakai (A&S) considers the promotion of sustainability, and its contribution to the achievement of Sustainable Development Goals(SDGs) that the international community aspires to, together with the realization of a prosperous and vibrant future through the SDGs, to be an
important social mission.
A&S has established a Sustainability Committee, chaired by the Chief Sustainability Officer (CSO) and composed ofeight lawyers, foreign lawyers, and other members, as a framework for promoting sustainability activities.
The Sustainability Committee promotes sustainability within A&S, identifies key sustainability issues and discusses policies for addressing such
issues, taking into account the contribution and impact on the firm's stakeholders, including clients, the environment, and society.
At present, the international community is faced with challenges such as the spread of coronavirus infections and their prolonged effects, thehumanitarian crisis in Ukraine and its neighboring regions, and natural disasters caused by climate change and extreme weather events, which
require the society to adapt rapidly. We have been working to meet these challenges by keeping a close eye on trends in the international
community, as well as changes in the society and the environment in which we operate. We will continue to promptly implement measures toensure the continuity of our business operations, as well as to identify social issues and needs, and contribute to building a sustainable and better
society for all.

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Our Firm
Global & Local oriented
Atsumi & Sakai became the first completely independent
Japanese law firm to create a foreign law joint venture
which offers a full range of legal services.
In the interest of realizing value for our clients, we createcomprehensive solutions from the perspective of legal
practice, tailored according to the demands of eachindividual case, all the while pursuing our mission to playa leading role in promoting the fair development ofbusiness and society and resolving complex issues
across a wide range of fields of expertise.

• Direct support from Tokyo, Fukuoka, New York, London and Frankfurt• Collaboration and cooperation with tier 1 law firms around the world• Backup activities of regional financial institutions and local businesses through regional
development projects which commenced in Japan about 10 years ago

Based on our multidisciplinary vision and creative
thinking that have been at the root of our Firm since its
inception, we strive to further improve the quality of ourinnovative, cutting-edge ability to provide solutions andvery convenient one-stop, complete services for ourclients, while also leveraging our extensive international
platform and unique collaboration structure.

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Our Recognitions© Atsumi & Sakai 2024

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Notable Achievements/ Various Projects/ Characteristics of A&S
Various Projects/ Characteristics of A&S

Notable Achievements• ESG and Sustainability Law Firm of the Year ALB Japan Law Awards 2023

Member of Ministry of
Economy, Trade andIndustry "GX League"• Pro bonoMember of Japan
Climate Leaders'Partnership (JCLP)

Acquired
Eruboshi certification

Participated as apromotion partner for
the "Corporate Action
for the Promotion ofCancer Control"
initiated by the Ministryof Health, Labor andWelfareLegal Professional
Corporation's General
Employer Action Plan

Introduction of a uniqueleave system so that
employee staff
undergoing infertility
treatment can balance
the treatment and work

Introduction of amentoring system for
employees returningfrom parental leave

Management
departments with highaverage overtime hours
will work to implement
no-overtime days.

Free legal advice
for staff• Nominated for the British Chamber of Commerce in Japan (BCCJ) British
Business Awards 2023 in the category of Responsible Business• Obtained high reputation in The Legal 500 Asia Pacific Green Guide 2024
(Issued by Legalease)© Atsumi & Sakai 2024

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Related Publications and Seminars (partial)
Publications• Project Energy Practice Team "Latest CCS Commercialization Trends in Japan"• A&S Newsletter "Business and Human Rights Newsletter" Series• "Human Rights Issues and Corporate Responsibility in Vietnam - Recent Case Studies" (June 30, 2023)• BUSINESS LAWYERS "Designing Compliance to Improve Corporate Brand: The Merging Point Between ESG/SDGs, Management, and Corporate Compliance"（September
2021）

Seminars• Hosted by Christopher Lee Ong (The Legal 360) on November 15, 2023
"Unveiling the Hidden Risks: Forced Labor Regulation, Supply Chain
Transparency, and HR Due Diligence - Is Your Company at Risk?"• Sponsored by the Financial Management Forums, Inc, September 12, 2023
"Renewable Energy and Electric Power Grid - Easy-to-understand explanationof the latest policies and issues related to electric power grids, including grid
storage batteries, self-commissioning, corporate PPA, output control, etc."• Sponsored by Japan Foreign Trade Council, Inc., July 13, 2023 "Economic
Security and 'Business and Human Rights' in Export Controls"• Sponsored by Kyushu University Department of Law, July 7,2023 "Discussion
with Students on Smart Cities/Super Cities"• Co-sponsored by Atsumi & Sakai, Smith, Gambrell & Russell, LLP and Sandler,
Travis and Rosenberg, P.A. and supported by the Japan Institute for Overseas
Investment June 28, 2023
"Human Rights in the Global Supply Chain Due Diligence - 'Forced Labor'
Compliance Issues in the U.S."• Sponsored by FRONTEO, Inc., June 8, 2023 “A comparative study of whatcompanies are expected to do with regard to business and human rights and theiractual initiatives: Aiming at further respect for human rights and enhancement ofcorporate value.“• Sponsored by International Bar Association, March 31, 2023
"4th Asia-based International Financial Law Conference"-"Environmental, social and governance (ESG) investment" (Speaker)• Sponsored bySumitomo Mitsui Trust Bank SMarT Knowledge Distributed on
February 7, 2023
“Outline of Guidelines for Respecting Human Rights in Responsible
Chains, etc. (based on Whistleblower System)"© Atsumi & Sakai 2024

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Seminars | The Legal 500 GC Summit JapanThe Firm was a featured participant at the session "The importance of
supply chain and human rights due diligence" at the Legal500 GC Summit
held in Tokyo in September 2023. The session focused in particular on thetheme of human rights due diligence, while also considering that supply
chain management is discussed from the perspective of sustainability,
economic sanctions, and others. The discussion delved into the heart ofsustainability and ESG.
Daniel Jarrett, Partner and registered foreign lawyer (The Laws of Englandand Wales) from the Firm, moderated this panel, and Takafumi Ochiai,
Senior Partner, attorney at law, and Head of the Prototype Policy ResearchInstitute, participated as a panelist. The other three panelists work forinternational companies and serve as general counsel in Tokyo, as follows:• Takayuki Kitajima, Japan general counsel, Unilever Japan Holdings;• Yoshinori Mochida, General Manager, Head of Legal Department,
Sony Semiconductor Solutions Corporation; and• Kazunari Fukuda, Japan Group Legal and Compliance Director, MoëtHennessy-Louis Vuitton (LVMH)

Although Japan does not have a law on supply chains and human rights due
diligence, the discussion took place against the backdrop that the Ministry of
Economy, Trade and Industry (METI) has issued "Guidelines on Respect for
Human Rights in Responsible Supply Chains". With this in mind, the panel
discussed a variety of topics, including:• challenges faced by large multinational companies in conducting thistype of due diligence;• the principal methods in which multinational companies engage orshould engage in such due diligence;• whether Japan should introduce relevant national legislation (similar
to Germany) or whether companies are able to self-regulate in thisarea;
• the role of in-house counsel in the design of the framework and its
implementation;• how law firms can help corporations and in-house counsel; and• how Japanese branches of multinational corporations are underpressure from overseas to address human rights due diligence issues.

In 2023, the German law on corporate due diligence in the supply chain
came into effect. The law significantly increases the requirements forcompliance and risk management systems in Germany, including extensive
due diligence obligations for companies with more than 3,000 employees.
From 2024, this will apply to companies with more than 1,000 employees.
Across Europe, the European Commission has published a draft Corporate
Sustainability Due Diligence Directive, indicating a clear potential for further
accelerated of efforts on a global scale.

While each company had a different view and approach, all agreed thathuman rights due diligence is becoming a more important consideration for
multinational companies, and that Japan is not immune to its influence.
It was an invaluable opportunity for the Firm to participate in this panelsession and to be involved in a stimulating discussion on this topic ofgrowing global importance.

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Seminars | Webinar co-sponsored by Japan Federation of Bar Associations and IBA
On October 2, 2023, the Japan Federation of Bar Associations and the

In response to the growing awareness of SDGs and ESGs in Japanese society,

International Bar Association (“IBA”) co-sponsored a seminar in a hybrid

this seminar was designed to share awareness of the issues within the legal

format entitled "How to Implement Effective ESG Strategies? Global Trends

industry, particularly with the next generation of attorneys, and further to deepenand Practical Issues". The Firm was involved in the seminar from thetheir knowledge and experience of global trends. The two panel discussions

planning stage, with attorney Takafumi Ochiai serving as the generalfeatured as panelists prominent practitioners at the forefront of the ESG field inmoderator and attorney Kentaro Minato and others moderating the panel

countries such as the UK, Netherlands, Australia, and other countries, who

discussion on the day of the seminar.

shared the latest findings from their respective countries. The subject matter of

The seminar consisted of two panel discussions, each of which provided anin-depth discussion of recent ESG topics. The First panel discussion, titled"Practice and Prospects of Human Rights Due Diligence in the World",
introduced the current situation surrounding human rights due diligence inthe UK, EU, Australia and Japan, followed by the hot topics of each country in
the field of "Business and Human Rights". This was followed by a panel

the conference was also designed with an awareness of "communication fromJapan" including an introduction to the latest trends in Japan presented by

Japanese attorneys. The panel discussion, including remarks by Japanese
attorneys, were conducted entirely in English, and through this, we believe thatparticipants were able to reaffirm that SDGs and the ESG field more generally arecommon global issues that transcend national borders.

discussion, titled "Disclosure Regulations of ESG Activities: Trends and

The seminar was a great success, with 56 participants attending both on-site

Considerations/ESG Disclosure Regulations", which shared the latest trends

and online. In the post-seminar survey, participants expressed their strong

in ESG disclosure in the UK, the Netherlands and Japan, together withinterest in SDGs and ESGs, with comments such as, "This is a timely topic, and I

examples of cases where disclosure violations were found to be problematic,

would like to make use of it in my future activities".

and various issues related to ESG disclosure in practice for each country.

We believe that this seminar provided a good opportunity for participants,
including those from the Firm, to gain interest and motivation in the ESG field forthe future.

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Features of Service
Contributing to Resolution of Global Issues by Leveraging our Worldwide Network

A&S is a full-service international law firm with offices in London, New York and Frankfurt.
In addition to our Japanese lawyers with extensive experience in international business, our roster(*3) includes a high number of registered foreign lawyers (*1)
and foreign attorneys (*2), enabling us to handle international matters in a timely manner. Furthermore, through our membership in several global networks andour own global connections, we partner and collaborate with leading law firms and other professionals around the world.
By utilizing these resources and our global network, we aim to engage in deeper dialogue with our clients from an international perspective and act together tocontribute to solving sustainability issues not only in Japan but throughout the world.

*1 Registered foreign lawyers whose jurisdiction of primary qualification are the laws of theState of New York, the State of California, Republic of China, Republic of Korea, India,
Democratic Socialist Republic of Sri Lanka, England and Wales and the State of Queensland,
Australia.
*Atsumi & Sakai is not subject to regulation by the Solicitors Regulation Authority of Englandand Wales.
*2 Foreign lawyers (but not registered foreign lawyers) whose jurisdiction of primary
qualification are the laws of the State of New York, the State of California, Irish Republic,
Israel, Socialist Republic of Vietnam, Republic of China and Taiwan.
*3 Registered foreign lawyers and foreign lawyers represent 11% of all attorneys at law,registered foreign lawyers and foreign lawyers.

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Area of Expertise
Security Trade Controls
https://www.aplawjapan.com/en/services/security-export-controls

Human Rights
https://www.aplawjapan.com/publications/20230824

Cybersecurity
https://www.aplawjapan.com/en/services/personal-information-protection-and-privacy

Renewable Energy, etc.
https://www.aplawjapan.com/en/services/energy

Environment / Global Warming Prevention
https://www.aplawjapan.com/en/services/environmental-law

National Security
https://www.aplawjapan.com/en/services/national-security

Agriculture, Forestry and Fisheries/Food
https://www.aplawjapan.com/en/services/protection-of-rights-in-agricultural-products-and-foods© Atsumi & Sakai 2024

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Initiatives to Solve Environmental Issues

We recognize that the preservation of the global environment is anurgent issue facing the entire world.
We will comply with the rules for environmental conservation in the
countries and regions in which we operate, as well as raise awarenessand promote sustainability within A&S, and strive to reduce ourresource use, energy consumption, and environmental impact. In ouroperations, we are also making efforts to reduce our environmental
impact by utilizing remote work, reducing the amount of paper we use,and saving electricity in our offices.

In the area of finance, which has long been a core area of the Firm’s
expertise, we support the environmental conservation efforts of various
financial institutions, including sustainable finance. A&S has endorsed
the Task Force on Climate-related Financial Disclosures (the TCFD),
and is committed to promoting climate-related disclosure.
We will utilize these achievements and our expertise to provide highquality legal services for environmental issues and contribute to theirresolution.

In addition, A&S has traditionally been actively involved in cases relating
to emissions trading, carbon offsetting, and the 3Rs (Reuse, Recycle,
Reduce), and is a member of the Ministry of Economy, Trade andIndustry's GX League for policy formation. In the renewable energy field,
we have been involved in a number of projects including biomass,
onshore and offshore wind power generation projects, etc. We also
provide support to government agencies, including by conducting
commissioned surveys as groundwork for further development. In
addition, we are enthusiastically working on domestic and international
policy and legal surveys and feasibility studies related todecarbonization in order to realize smart city and zero emissions
projects.

GX League
TCFD

LIMEX

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Participation in the GX League (energy conservation awareness activities, etc.)
Background of GX League Participation
METI has explained the importance of Japan leading in relation to GX and the purpose of launching the GX League as follows.
In order for Japan to achieve its 2050 carbon neutrality goal and contribute to the realization of carbon neutrality on a global scale, and to seize
opportunities for growth and increase its industrial competitiveness, it is essential for Japan to take on the challenge of transferring to carbon neutrality
as quickly as possible and to be competitive in the international business arena, with a "group of companies" driving and transforming the entire
economic and social system, including stakeholders other than themselves (GX: Green Transformation).
To this end, the "GX League" will be established as a place where a "group of companies" actively engaged in GX, together with players in government,
academia, and finance who are taking on the challenge of GX, can work as one to discuss the transformation of the entire economic and social systemand to practice the creation of new markets.
Source: METI website, "GX League Basic Concept": GX League Basic Concept (METI/Ministry of Economy, Trade and Industry)

The GX League has established the following three goals with the aim of creating a society (with a virtuous cycle between the economy, environment,
and society) in which companies that take on the challenge of GX can contribute to emissions reductions while also achieving growth that isaccurately evaluated from external perspectives:(i) Demonstrate the kind of leadership that enables companies to make a contribution to the world;(ii) Those able to effectively balance GX and innovation and swiftly embrace the challenges and practices of the transition will be chosen by
consumers that allows for appropriate "profitability"; and(iii) GX investments by companies create a system supported by financial markets, labor markets, and civil society.
Source: GX League website "ABOUT GX LEAGUE": ABOUT｜GX League Preparation Official Web Site (gx-league.go.jp)© Atsumi & Sakai 2024

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Members• The Firm regards the promotion of sustainability as a crucial social mission, which contributes to the achievement of the Sustainable Development Goals(SDGs) advocated by the international community and the realization of a prosperous and vibrant future through the SDGs.
In demonstrating the Firm's belief, the Sustainability Committee was established to promote sustainability within, identifies key sustainability issues anddiscusses policies for addressing them, taking into account their contribution to and impact on the Firm's stakeholders, including clients, the environment,
and society.
• The GX League, spearheading challenges towards GX with the collaboration of the Japanese Government, academia, and financial sectors, has attracted
significant attention with numerous companies expressing their interest in participation. Its philosophy aligns closely with the Firm's efforts towards
addressing environmental issues. By engaging in in-depth discussion regarding GX with GX League member companies, the Firm further refines its
commitment towards reducing its environmental impact.
• In addition to the GX League, the Firm also participates in the Japan Climate Leaders Partnership (JCLP), which was formed based on the recognition thatindustry must have a healthy sense of urgency and initiate proactive action to achieve a sustainable decarbonized society. As a law firm, the Firm also
promotes responsible initiatives through participation in both public-private collaborative settings and private initiatives.
• Attorneys Mr. Ochiai and Mr. Hirayama participated as members in the "GX Human Resources Market Creation WG" (a WG to organize professional humanresources types, design two calculation and reduction plans to Levels 1-4, organize learning items for literacy acquisition, and discuss the definition of
acquisition content required for literacy level (1)), which is being conducted by the GX League as a "place to formulate market rules" initiative.
• In addition, Attorney Mr. Ochiai is a member of the GX League's "Qualified Carbon Credit WG".
• Developed and published the Firm's transition strategy in light of its participation in the GX League.

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Endorsement towards the Task Force on Climate-related Financial Disclosures(the TCFD), and is committed to promoting climate-related disclosure
The Firm endorses the Task Force on Climate-related Financial Disclosures (TCFD) and is a member of the TCFD Consortium. We are working with the TCFD
Consortium to promote climate-related disclosure.

Introduction of LIMEX
We have started to use LIMEX, an environment-friendly material made primarily from limestone, for certain of ourprinted materials.
("LIMEX" is a registered trademark of TBM Co., Ltd.)© Atsumi & Sakai 2024

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Our efforts as a law firm (Using Our Law Firm Expertise to Support the
Growth of Communities and the Society)
Our mission is to create comprehensive solutions tailored for each case from a legal practice perspective in order to create value for our clients, and tosimultaneously play a leading role in promoting the fair development of a business society.

To date, we have been actively engaged in new and contemporary areas, and have taken on the challenge of solving a variety of complex and diverse issues. The
Prototype Policy Research Institute established by the Firm is dedicated to bridge gaps between new policies and practice, as well as to publish researchfindings and recommendations. In November 2023, the Firm also newly established a pro bono team to assist foreign residents in Japan to obtain legal services.

* Posted on A&S website
in multiple languages
The 30 rule makers in Japan (Forbes
JAPAN No. 096, 2022)

Furthermore, the Firm has consistently demonstrated an awareness of the importance of local regions, including by supporting regional financial institutions andsmall- and medium-sized enterprises. This plays an important role in regional development, and the Firm is committed to the sound development of local
companies that support the Japanese economy and provide solutions to regional issues.
By further promoting these activities and making full use of the knowledge and experience we have accumulated as a law firm, we will strive to support thesustainability of society as a whole.

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Respect for Human Rights
Business and Human Rights
Article 1 of the Attorneys Act provides that the mission of attorneys is to protect fundamental human rights and achieve social justice.
The Firm actively practices and promotes: pro bono activities, bar association activities, court-appointed defense counsel activities, lectures on legal subjects atuniversities and graduate schools, mentoring legal apprentices, participating in review meetings at public institutions, and other public interest activities that are
essential for the realization of our mission as a law firm.

Recently, the concept of "Business and Human Rights", initiated by theUnited Nations, has been gaining global acceptance, and there has been agrowing movement to demand respect for human rights from corporations.
In Japan, the Government established standards such as the Guidelines for
Respecting Human Rights in Responsible Supply Chains, recommending
corporations to formulate human rights policies, conduct human rights due
diligence, and ensure remedies for human rights violations. In July 2023,
the OECD revised its Guidelines for Multinational Enterprises on
Responsible Business Conduct, to clarify the scope of application of due
diligence on supply chains. The Ministry of Economy, Trade and Industry
has also released Reference Materials on Practical Approaches for
Business Enterprises to Respect Human Rights in Responsible Supply
Chains to clarify the operation of the above Guidelines. In addition, the UN
Human Rights Council's Working Group on Business and Human Rights
visited Japan and issued a statement on the situation of business andhuman rights in Japan.

In order to promote the strengthening of corporate efforts to respecthuman rights, the Firm regularly publishes newsletters on Business andHuman Rights which aim to update the status of legislation andenforcement regarding respect for human rights in Japan, the UK, the US,
the EU, and other countries, as well as to explain specific measures forrespect for human rights that corporations should implement. We havealso issued announcements emphasizing the importance of human rights
due diligence as responsible corporate behavior at a seminar co-hosted by
Japan Federation of Bar Associations and International Bar Association(IBA) regarding the introduction of ESG strategy (held in October 2023), theGS Summit Japan 2023 hosted by The Legal 500 (held in September 2023)
and on other occasions. In recognition of these activities, the Firm wasawarded ESG and Sustainability Law Firm of the Year at the Asian Legal
Business (ALB) Japan Law Awards 2023.

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Respect for Human Rights
U.K. Anti-Slavery Act (supplier questionnaire) | Background
The UK Modern Slavery Act 2015 (the "Modern Slavery Act") requires foreign companies and their subsidiaries that meet the stipulated financial requirements,
and that do business in the UK, to prepare and publish a statement on slavery and human trafficking for each fiscal year.

Since Atsumi & Sakai Legal Professional Corporation provides legal
services in the UK through our office in London, in June 2023 the Firm
published an Anti-Slavery and Human Trafficking Statement on our website
as required under the Modern Slavery Act for the business year ending
December 31, 2022. This statement discloses the measures taken by
Atsumi & Sakai Legal Professional Corporation and its group ("A&S") toensure that slavery and human trafficking are not taking place in any part ofits operations and supply chain.

However, A&S is aware that slavery and human trafficking may exist in
jurisdictions in which the Firm operates its business and procures goods orservices. Therefore, A&S is actively taking appropriate measures to ensurethat neither slavery nor human trafficking exists in its operations, supply
chains or other related activities.

A&S is engaged in a client-focused professional services businessconsisting of full-time attorneys and registered foreign lawyers in a strictly
regulated industry. As such, we believe that the risk of slavery or humantrafficking occurring within A&S's operations or direct supply chain is low.
In fact, slavery or human trafficking has never been identified in A&S’
supply chain.

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Respect for Human Rights
U.K. Anti-Slavery Act (supplier questionnaire) | Details of actions taken at the Firm

We have internal rules, etc. in place including Atsumi & Sakai Legal Professional Corporation Rules on Ethics and the Code of Conduct and Basic Policy on
Prevention of Slavery and Human Trafficking.
These rules, etc. clearly state that modern slavery is a crime and is a violation of basic human rights, and also include: a human resources policy to ensure aworking environment based on respect, fairness, trust, support, and transparency; a reporting system and complaints processing procedure; and anti-bribery
and anti-money laundering policies.
• We are also working to establish a supply chain compliance system.
To ensure that all those involved in the supply chain and contractors adhere to the values of A&S, we have established the Atsumi & Sakai Legal Professional
Corporation Supplier Policy, with which suppliers are required to comply.
• We conduct questionnaire surveys of our direct suppliers to identify and assess potential risk areas in the supply chain and monitor risk areas.
• We also provide annual training on the Modern Slavery Act to all of our attorneys, foreign lawyers and staff members in order to ensure a high level ofunderstanding regarding the risks of slavery and human trafficking in the A&S supply chain and operations.

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Respecting Diversity and Creating a Positive Work Environment
Gender Equality/LGBTQ
We have established support systems for maternity leave, childcare leave and returning to work including babysitting support. We were one of the first Japanesefirms to implement basic policies for the prevention of sexual and power harassment. All of these contribute to creating a healthy work environment where
employees can work and feel comfortable without having to be conscious of their gender, sexual orientation, or gender identity.
In addition, attorneys of the Firm participate as instructors in external seminars on sexual harassment and power harassment prevention, thereby contributing to
the development of fair and equitable work environments in the broader society.
Since our early days, many female attorneys and staff members have flourished in A&S. Our New York affiliate office is headed by a female attorney, and manyfemale attorneys also serve in managerial roles and lead activities in our practice groups.
The percentage of women among partners at Atsumi & Sakai is 25%, and 35% among foreign lawyers, etc., and 90% among staff members in managerial
positions.

Some awards received by Atsumi & Sakai's lawyers in rankings and awards
focused on the participation of women in the law:•

IFLR1000 Women Leaders 2022 (Miho Niunoya was one ofeight women selected in the Japan category)•

ALB Asia’s Top 15 Female Lawyers 2021 & 2022 (Miho Niunoya(2021) and Yuri Suzuki (2022) were selected as one of 15
attorneys in their respective years, as the only attorneys fromJapan)•ALB Japan Law Award 2017 “Woman Lawyer of the Year”(Setsuko Yufu)© Atsumi & Sakai 2024

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Our Approach to
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Members

Respecting Diversity and Creating a Positive Work Environment
Various in-house systems that support diverse work styles
Attorneys

The Firm respects and encourages a flexible working style that suits each individual's life stage and situation.
The Firm has established a comfortable teleworking environment through the use of remote working tools and online conferencing systems, and have also
adopted a free address seating system.
Since attorneys work under service contracts, we do not manage their holidays, but the following compensation guarantee rules apply during their long-term
leave of absence due to injury or illness:"In the event that an attorney, etc. is absent from work for an extended period of time due to injury or illness for reasons other than willful misconduct orgross negligence, 60% of such person's base annual compensation (not including bonuses) shall be guaranteed for one year (but not exceeding JPY
1,000,000 per month) during such period of absence. In the event that the need for compensation guarantee arises beyond the amount above (including
leave of absence exceeding one year), additional compensation guarantee may be provided at the discretion of the Firm or the Firm's emergency loan
program may be made available."

In addition, a mentoring system has been established to facilitate mutual understanding and to provide career support for young associates, which includes
holding regular interviews.

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Members

Staff & Members

The Firm has introduced a variety of programs respecting diversity that are available for staff members at various stages of their life.

(i) Flexible special leave for injury or illness (sick leave)(ii) Other systems that support diverse work style◼ Background◼ Leave of absence due to illness or injury

Although there was already a system of Time Off for Sick/Injured
Childcare/Short-term Leave for Caregivers in the Childcare/Caregiver
Leave Act, this was unpaid. As such, we have made it possible for
employees to apply for sick leave and nursing care of family members
under the sick leave system to make the system easier to use.

When a staff member takes a leave of absence due to non-work related
illness or injury, their wages shall be paid for two months commencing
from the day on which the leave of absence is ordered to commence.
◼ Handling of salaries, etc. during extended family-care leave◼ Description of the system
Holidays are granted to all staff members and are available during theprobationary period if requirements are met. Although student part-timeworkers and some other employees are not eligible, the system can better
meet the more diverse needs of staff members compared the previous
system. For example, unlike the previous Time Off for Sick/Injured
Childcare/Short-term Leave for Caregivers, there are no restrictions on"taking care of a child until the child reaches the age of 4th grade ofelementary school”.

When a staff member who cares for a family member in need of nursing
care takes extended family-care leave, wages may be paid for 40 days
from the day on which the leave commences.

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Members(iii) 1 on 1 meetings with managers(iv) Infertility treatment leave◼ BackgroundAs a general employer action plan under the Act on Advancement of
Measures to Support Raising Next-Generation Children, we are planning
to introduce a unique leave system for staff members undergoinginfertility treatment to balance treatment and work from the period from
July 1, 2022 to June 30, 2024. As we have already included shortening ofworking hours, teleworking, and extended childcare leave in ourmaternity/paternity and childcare related systems, our action plan
focused on supporting staff members undergoing infertility treatment tobalance the treatment with their work.

As an increasing number of staff members now work from home, it has
become difficult to fully monitor the situation of co-workers. This has led
to the introduction of 1 on 1 meetings with managers.
◼ Description of 1 on 1 meetings
Each staff member has a 1 on 1 online meeting with their manager once amonth. The purpose of this system is wide-ranging, including mutual
understanding regarding private life, checking physical and mental health,understanding what is happening in the office, solving work-related
problems, improving motivation and career support, checking on the
progress of goals, and reverse reporting from supervisors on matters suchas communicating work policies. Of course, it also functions as a meansof harassment prevention and internal reporting mechanism.

We also aim to acquire the certification of “Kurumin Plus” in the future.
• The Firm's website “Atsumi & Sakai Legal Professional Corporation ,General Employer Action Plan”:
https://www.aplawjapan.com/news-events/20220909• Ministry of Health, Labour and Welfare website“Act on Advancement of Measures to Support Raising Next-Generation
Children”:
https://www.mhlw.go.jp/stf/newpage_11367.html• In relation to Kurumin Plus, Ministry of Health, Labour and Welfare“To balance infertility treatment and work”:
https://www.mhlw.go.jp/stf/newpage_14408.html© Atsumi & Sakai 2024

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Members

Respecting Diversity and Creating a Positive Work Environment
Promotion of Health for All and Systems Supporting Wellness and Diversity
Both the mind and body are essential for wellbeing and the Firm is committed to supporting staff members and attorneys equally.

We have contracts with three occupational physicians who specialize (respectively) in internal medicine, psychiatry, and psychosomatic medicine. They areavailable for in-person/online consultation with employees when needed. A full-time public health nurse is also available for regular health consultations.
In addition to medical checkups for both attorneys and staff members under the Industrial Safety and Health Act, those over 35 years of age are eligible forcomprehensive medical checkups at the full cost of the Firm. If any abnormality is found, the Firm also provides individual support after checkups byrecommending treatment and providing opportunities to see an occupational physician.
In addition to recommending regular medical checkups/ comprehensive medical checkups at the full cost of the Firm, we have joined the "Corporate Action to
Promote Cancer Control" initiative of the Ministry of Health, Labour and Welfare as a promotion partner to improve cancer awareness, and share information via
our in-house social media platform.
We also conduct annual stress checks under the Industrial Safety and Health Act for staff members and attorneys, to encourage awareness of their own stresslevels. We then recommend consultation with an occupational physician or outside consultation service when individual support is required for staff with highstress level, and also conduct group analysis by job classification to study improvements in the workplace environment.

For those who have illnesses, injuries, or disabilities, the occupational physician, public health nurse, and HR staff work together to provide the necessary
support for work options. We also provide support for personnel on a leave of absence due to injury or illness in accordance via our reinstatement support
program.
Finally, we hold online health seminars and regularly share health information via our in-house social media and health management system to improve healthawareness, including for those working from home.
(Note) Staff members work under labor contracts and attorneys work under service contracts.
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Introduction of Members

Attorney
Yuri Suzuki

Senior Partner
Chief Sustainability
Officer

Education/Work Experience:

Education/Work Experience:

Graduated from Waseda University Department of Law and New York
University School of Law (LL.M.). Guest Attorney, Kirkland & Ellis
LLP (Chicago, IL office), 2005-2006. Auditor of The Organization of
Global Financial City Tokyo, Member of the Committee for the
Formulation of Individual Member of the Individual-type Pension Policy
Formulation Committee of the National Pension Fund Association, andChairman of the Finance and Securities Transaction Committee of theInter-Pacific Bar Association (all to date).

B.A. in Law, Hitotsubashi University, Northwestern University Schoolof Law (LL.M.). Outside Director of PARK24 CO., LTD. (January 2020-),
External Auditor of Sony Financial Group Inc. (June 2023-), Member of
METI's "Study Group on the Appropriate Implementation andManagement of Renewable Energy Generation Facilities"(2022-2023),
Expert Member of Committee for Promotion of Private FinanceInitiatives Projects, Cabinet Office, Government of Japan, etc.

Main Practices:
Financial Transaction / Financial Regulation / ESG Investments /Economic Security / M&A/Internal Investigation/ International Dispute
Resolution/ North America/ Taiwan /Vietnam/ Indonesia, etc.

Attorney
Miho Niunoya

Senior Partner
Sustainability Officer

Senior Partner
Sustainability Officer

Corporate Governance / Diversity, Renewable Energy Business,
Infrastructure Business, PPP/PFI Business, Environment / Global
Warming Countermeasures, Support for Expansion into India andSoutheast Asia, etc.

E-mail: yuri.suzuki@aplaw.jp

E-mail: miho.niunoya@aplaw.jp

Education/Work Experience:

Education/Work Experience:

B.A. in Law, University of Tokyo, Vanderbilt University School of
Law(LL.M.). Joined the firm in 2005. September 2010 - June 2011 at
Luther Rechtsanwaltsgesellschaft mbH (Dusseldorf).

B.A. in Law, Chuo University, University of Southern California (USC)
Gould School of Law (LL.M.). Joined Nishimura & Asahi in 1999-2019,and A&S in 2020. Outside Director of SBI Sumishin Net Bank, Ltd.
(January 2021-)

Main Practices:

Attorney
Eiichiro Hata

Main Practices:

Cross-border Investment and Funds / Financial Regulation / M&A /Real Estate Financing and REITs / General Corporate Legal Affairs /E-mail: eiichiro.hata@aplaw.jp

Attorney
Yukihito
MachidaPartner
Sustainability Officer

Main Practices:
Financial Regulatory Lay(regulatory) / Venture Finance / AssetManagement and Investment Funds / Corporate Governance /General Corporate Legal Affairs / Start-up Practice (venture support) /M&A and Corporate Reorganization /Private Equity / Advice regarding
Disclosure of Business Content

E-mail: yukihito.machida@aplaw.jp© Atsumi & Sakai 2024

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Introduction of Members
Education/Work Experience:

Education/Work Experience:

Registered
Foreign Lawyer

Graduated from the University of Cambridge (LL.B.), Utrecht University(Law) and The University of Law (LPC).
2011-2016 Ashurst (London); 2016-2022 Ashurst HJGKJ (Tokyo); 20172019 seconded to Mitsui & Co.'s Legal Department (Tokyo); joined A&S
in 2023.
Solicitor admitted in England & Wales (2013)
Registered Foreign Lawyer (The Laws of England & Wales) (2016)(The Laws ofEngland & Wales)

Main Practices:

Partner

E-mail : daniel.jarrett@aplaw.jp

DanielJarrett

Project Finance and PPP / Maine Logistics /Aircraft, Ship, and Asset
Finance / Transportation and Infrastructure / Renewable Energy

Attorney
Takafumi
Ochiai

Senior Partner
Head of Prototype
Policy ResearchInstitute

B.S. in Mathematical Sciences, Faculty of Science and Technology, Keio
University, M.S. in Science and Technology, Graduate School of Science andTechnology, Keio University
Passed the former bar exam while in graduate school and joined Mori Hamada& Matsumoto from 2006-2015 and A&S from 2015.
Responsible for the Emerging Industry team, Singapore team and A&S
Newsletter "Business and Human Rights Newsletter" Series. Chairperson ofStartup and Investment WG of the Cabinet Office's Council for Promotion ofRegulatory Reform, the deputy chairperson of the National Strategic Special
Zone WG of the Cabinet Office, member of the Digital Agency's Study Group on
Reform of Digital-related Systems, member of the METI Trade Field Data
Linkage WG, member of the MIC's Study Group on How to Ensure Sound
Information Distribution in Digital Space, and member of the Health, Medical,
and Long-Term Care Information Use Study Group of the MHLW. Member ofthe Working Group on Secondary Use of Medical Information, Health, Medical
Care and Nursing Care Information Utilization Study Group, Ministry of Health,Labour and Welfare, Advisor to Fukuoka International Finance City, Fukuoka
Prefecture, and others.

Main Practices:

Technology / Privacy and Industry Data / Financial Regulation Law/ Medical
Regulation Law / Trade Transactions /International Human Rights/ M&A/
Dispute Resolution (International Arbitration)/ IP

E-mail: takafumi.ochiai@aplaw.jp
Education/Work Experience

Attorney
Katsunori Irie
Of Counsel

B.A. in Economics, Keio University, graduated Keio University Law
School.
Registered as an attorney in 2009. After working for a Japanese law firm,
since 2015, he has been working for the Japan International Cooperation
Agency (JICA) providing legal support to countries in Southeast Asia.
Visiting Scholar, The U.S.-Asia Law Institute New York University Schoolof Law.
Current position from 2023. Member of the Center for Promotion ofInternational Legal Services of Japan Federation of Bar Associations,
Secretary of Business and Human Rights Section, the Committee on
International Human Rights

Main Practices:

Education/Work Experience

B.A. in Law, Waseda University (2004) and graduated Tohoku University
Law School (2007). University of Southern California (USC) (LL.M. in
ADR Certificate) (2017),
University of California Los Angeles (UCLA) (LL.M. in BusinessSpecialization, Business Law Track) (2019),
Hayachine Law Office (December 2011-January 2016), Creek andGlobal, Inc. (Legal Counselor, May 2017-July 2018).

Attorney
Chihiro Saito
Of Counsel

Vietnam, Laos and other Southeast Asian legal affairs / Business andHuman Rights / Sustainability and ESG Legal Affairs / Corporate / Labor /M&A, etc.

Main Practices:

Corporate Governance / General Corporate Law / International
Litigation (Cross-border Disputes/International Litigation) / Life
Sciences

E-mail : chihiro.saito@aplaw.jp

E-mail: katsunori.irie@aplaw.jp© Atsumi & Sakai 202427

Legal Notices
1. ABOUT ATSUMI & SAKAI
Atsumi & Sakai is a partnership consisting of Atsumi & Sakai Legal Professional Corporation, a Japanese professional corporation, a foreign law joint venture under the Act on Special
Measures Concerning the Handling of Legal Services by Foreign Lawyers with certain Registered Foreign Lawyers of our firm, a Japanese Civil Code partnership among Japanese lawyers,
represented by Yutaka Sakai, a lawyer admitted in Japan, and a foreign law joint venture with Janssen Foreign Law Office, represented by Markus Janssen, a foreign lawyer registered inJapan to advise on the laws of the Federal Republic of Germany. In addition to lawyers admitted in Japan, our firm includes foreign lawyers registered in Japan to advise on the laws of the
US States of New York and California, the People's Republic of China, the Republic of Korea, India, the Democratic Socialist Republic of Sri Lanka, England and Wales*, and the State ofQueensland, Australia. Foreign lawyers registered in Japan to advise on state laws also are qualified to provide advice in Japan on the federal laws of their respective jurisdictions.
Atsumi & Sakai has established an office in London operating as Atsumi & Sakai Europe Limited (a company incorporated in England and Wales (No: 09389892); sole director Naoki
Kanehisa, a lawyer admitted in Japan), and has established an affiliate office in New York operating as Atsumi & Sakai New York LLP (a limited liability partnership established in New
York; managing partner Bonnie L. Dixon, a lawyer admitted in New York and a Registered Foreign Lawyer in Japan). We also have a partnership with A&S Fukuoka LPC in Japan (partner:
Yasuhiro Usui, a lawyer admitted in Japan) and an affiliate office in Frankfurt operating as Atsumi & Sakai Europa GmbH - Rechtsanwälte und Steuerberater, a corporation registered inGermany providing legal and tax advisory services (local managing director: Frank Becker, a lawyer admitted in the Federal Republic of Germany).
* Atsumi & Sakai is not regulated by the Solicitors Regulation Authority for England and Wales.
2. LEGAL ADVICEJapanese legal advice provided by Atsumi & Sakai and our global offices is provided by lawyers admitted in Japan. Advice provided in Tokyo in respect of any foreign law on which one of
our foreign lawyers is registered in Japan to advise, may be provided by such a Registered Foreign Lawyer. None of Atsumi & Sakai Legal Professional Corporation, Atsumi & Sakai Europe
Limited or Mr. Naoki Kanehisa is regulated by the Solicitors Regulation Authority for England and Wales, and none will undertake any reserved legal activity as defined in the United
Kingdom Legal Services Act 2007. Advice provided in Germany on the laws of Germany will be provided by a lawyer admitted in Germany, and advice provided in New York on the laws of
New York will be provided by a lawyer admitted in New York.

© Atsumi & Sakai 2024