Second Opinion
Sumitomo Corporation

February 22, 2024

Sustainable Finance Framework

ESG Division
Mami Arai

Rating and Investment Information, Inc. (R&I) has confirmed the alignment of the Sustainable Finance
Framework of Sumitomo Corporation formulated in February 2024 with Green Bond Principles 2021, Social
Bond Principles 2023 and Sustainability Bond Guidelines 2021 of the International Capital Market Association(ICMA), and Green Loan Principles 2023 and Social Loan Principles 2023 of the Loan Market Association, theAsia Pacific Loan Market Association and the Loan Syndications and Trading Association. This opinion isbased on the following views:■ Overview of the Opinion(1) Use of Proceeds
The proceeds will be allocated to green projects and social projects. The eligibility criteria is clearly
defined with corresponding project categories illustrated in the ICMA and other principles, and clear
environmental benefits and social outcomes are expected. Green eligible projects include the renewableenergy generation business, the battery storage business, the forest management business, theoperation and maintenance of urban passenger railways, base station sharing services, the development
and acquisition of energy-efficient properties, the development and operation of water infrastructure, andthe development and acquisition of green buildings. Social eligible projects are the telecommunications
business and financial services in geographically and socio-economically disadvantaged areas, targeting
those underserved owing to a lack of quality access to essential services. These initiatives are designed
to bridge the digital divide and achieve financial inclusiveness. With the companywide risk management
framework in place, negative environmental and social impacts from project implementation are
managed appropriately. The use of proceeds is reasonable.
(2) Process for Project Evaluation and Selection
Eligible projects are consistent with the Sumitomo Corporation Group's material issues and key social
issues, and the finance under the Framework is positioned as that aimed at practicing the Management
Principles. A process is in place where the Finance Department, with the cooperation of the Corporate
Sustainability Department, selects projects and the final decision is made by the Chief Financial Officer.
The involvement of the department with ESG expertise enables the comprehensive examination ofeffects and risks of projects. The process for project evaluation and selection is clear and rational.
(3) Management of Proceeds
The Finance Department will track and monitor the proceeds. Any unallocated funds generated from thesale of assets or other events will be reallocated to other eligibility projects. The unallocated funds will be
managed in cash or cash equivalents. The management of proceeds is appropriate.
(4) Reporting
Sumitomo Corporation will disclose the allocation of proceeds, environmental benefits and social
outcomes within around one year after the funds are raised. Environmental benefits will be disclosed
mainly using quantitative indicators, and social outcomes will be reported in terms of output, outcome
and impact. The reporting is appropriate.

Rating and Investment Information, Inc.

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Second Opinions are R&I's opinions on the alignment of a framework, formulated by companies etc. to raise funds for the purpose of environmental conservation and social
contribution, with the principles etc. compiled by public organizations or private organizations related to the relevant financing as of the date of assessment and are notstatements of fact. Further, R&I does not state its opinions about any matters other than the alignment, certify outcomes, give advice regarding investment decisions or
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to Second Opinions. As a general rule, R&I issues a Second Opinion for a fee paid by the issuer. For details, please refer to the end of this document.

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Outline of the Issuer


Sumitomo Corporation is a leading general trading firm of the Sumitomo Group. It runs a wide range ofbusinesses globally with the six business units of Metal Products, Transportation & Construction
Systems, Infrastructure, Media & Digital, Living Related & Real Estate, and Mineral Resources, Energy,
Chemical & Electronics. In 2021, Energy Innovation Initiative (EII) was established as a new organizationthat goes beyond divisional boundaries. By taking a cross-organizational approach, the unit aims tocreate next-generation businesses that contribute to realizing a carbon-neutral society.



At the core of the company's Management Principles and Activity Guidelines stands Sumitomo's
Business Philosophy, which has been passed down since its founding in the 17th century. One of thephrases that encapsulate the philosophy is "Benefit for self and others, private and public interests are
one and the same." This expresses the idea that Sumitomo's business, while benefiting Sumitomo, mustalso benefit the nation and benefit society, which represents Sumitomo Corporation's Corporate Vision.

In 2017, Sumitomo Corporation identified six material issues based on Sumitomo's Business Philosophy
and Management Principles. These material issues clarify the company's approach to social
contributions through its businesses as well as management issues, positioned as important elements inthe establishment of business strategies and in the decision-making process for individual businesses.
As part of the efforts to enhance sustainability management, in 2020 the company identified six key
social issues that are particularly relevant to its business activities from among the social issues facing
the world, and set out medium- and long-term targets to address each issue. Sumitomo Corporation isfirmly committed to the realization of a sustainable society by being constantly aware of the relationshipbetween its business activities and social issues in regard to material issues and key social issues.

[Sumitomo Corporation website]

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1. Use of Proceeds(1) Eligible Projects
The proceeds will be used to finance or refinance projects that meet the following eligibility criteria. In thecase of refinancing, the projects implemented within around three years are eligible. If the proceeds areallocated to the projects implemented more than three years before, Sumitomo Corporation will confirm
and explain the sustainability of the projects' environmental benefits and social outcomes at the time ofrefinancing.
<Green Projects>
Project Category

Eligibility Criteria
 Wind power generation

 Solar power generation
Renewable energy Geothermal power generation (Directemissions less than 100g-CO2/kWh) Battery storage business with gridstability

Environmentally
sustainable
management of living
natural resources andland use

Acquisition, utilization and maintenanceof forest assets based on the Sumitomo
Corporation Group Forest Management
PolicyClean transportation

Operation and maintenance of urban
passenger railways

Energy efficiency

 Base station construction andoperation necessary for providingbase station sharing services centeredon 5G to mobile network operators
 Development, construction,
renovation, acquisition, etc. of
properties which have received or are
expected to receive BELS 5 stars

Sustainable water and  Water supply
wastewater Sewerage management
management
 Related equipment and pipes

Green buildings

Development, construction, renovation
and acquisition of properties which havereceived or are expected to receive agreen building certification

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SDGs

Second Opinion<Social Projects>

Project Category

Access to essential
services

Eligibility Criteria
The following businesses in
geographically andsocio-economicallydisadvantaged areas(developing countries in
Asia, Africa, etc.)
 Telecommunications
business with solution ofdigital divide Financial services toenhance financial
resilience/stability

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TargetPopulation

Underserved,
owing to a lackof quality
access toessential
services

SDGs

Second Opinion(2) Project Categories, Environmental Benefits and Social Outcomes of Eligible
Projects① Renewable energy generation and battery storage businesses
Project Category: Renewable energy
Project Summary: The proceeds will be allocated to wind, solar and geothermal power generation
projects and the battery storage business for grid stability. Eligible geothermal power generation projects
are limited to those with direct emissions of less than 100g-CO2/kWh. The battery storage business will
install large battery storage equipment that can be connected to the power grid.
Environmental Benefits: The use of renewable energy as a main source of power is indispensable forthe global trend of carbon neutrality. Sumitomo Corporation runs renewable energy generation
businesses in and outside Japan with an extensive track record in wind, solar and geothermal power
generation. The company set a target of increasing its renewable energy net ownership generation
capacity to 5GW or more by 2030 from 2.1GW as of June 2023. Sumitomo Corporation will contribute to
CO2 emissions reduction through aggressive business development aimed at achieving this target.
Meanwhile, it is difficult to adjust the supply-demand balance of renewable energy in the power gridbecause power generation is greatly affected by sunlight and weather conditions. In Japan, theinsufficient capacity of transmission lines to the power grid, as well as of tie lines for flexible power
exchange between regions, is causing output restrictions on renewable energy nationwide. To addressthese grid constraints that hamper the spread of renewable energy in Japan, Sumitomo Corporation will
promote the installation of large-scale battery storage facilities for the power grid. The facilities will adjust
the surplus or deficiency of renewable power generation by charging and discharging battery storages,
and realize stable supply of grid electricity while using renewable energy efficiently. In addition to theinstallation of new battery storages, a unique initiative is underway to install battery storage systems thatutilize reused batteries from EVs. Sumitomo Corporation is working together with 4R Energy Corporation,a joint venture with Nissan Motor Co., Ltd., to build a scheme that allows the reuse of waste batteries,
which will increase in line with the widespread adoption of EVs, and also help reduce CO2 emissions in
the process of manufacturing new batteries. It will expand the energy storage business primarily in
Hokkaido and Kyushu, regions with a substantial need for grid stability.

[Sumitomo Corporation website]② Acquisition, utilization and maintenance of forest assets
Project Category: Environmentally sustainable management of living natural resources and landuse
Project Summary: The proceeds will be allocated to the acquisition of new forest assets and logging,planting and other activities in forests owned by Sumitomo Corporation. The company has a groupwide
framework for sustainable forest management with lower environmental and social risks based on theForest Management Policy, which was established by incorporating advice from external specialized

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organizations and other entities. Forest projects implemented in accordance with the policy are eligible
for the use of proceeds.
Environmental Benefits: Forests are important common resources of mankind in environmental, socialand economic aspects, with multi-faceted functions such as maintaining biodiversity, protecting water
sources and stabilizing soil. As global warming accelerates, another forest function of absorbing andfixing CO2 is also drawing more attention. Carbon credits are used globally as an effective tool forachieving carbon neutrality, and the forest sector accounts for a large proportion of the total credits
issued. To maintain and improve forest functions, appropriate forest management is vital. Sumitomo
Corporation has been actively acquiring and managing forest assets in many countries, as exemplified
by its engagement in forest management in New Zealand through a subsidiary since 2013. In
accordance with its Forest Management Policy, Sumitomo Corporation promotes appropriate forest
management through well-planned thinning and planting from a long-term perspective while caring forthe environment and building dialogue and relationships with local stakeholders. It will consider supplying
unused quality wood, such as wood from thinning, to the market in order to further the efficient utilizationof forest resources. With sustainable forest management through a harmonious arrangement with local
communities, the company will protect ecosystems, improve the forest function of water source
protection and maximize the amount of CO2 absorbed and fixed.
[Sumitomo Corporation Group Forest Management Policy][Sumitomo Corporation website]③ Operation and maintenance of urban passenger railways
Project Category: Clean transportation
Project Summary: The proceeds will be allocated to businesses related to the development, operationand maintenance of railway infrastructure in foreign countries.
Environmental Benefits: Rail is an environmentally friendly transportation infrastructure, emitting less

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CO2 per passenger kilometer than other transportation modes. A modal shift in transportation from cars
to rail is effective as a climate change solution. Moreover, chronic traffic congestion and air pollution incountries facing rapid population growth and urbanization are increasing the need to develop a public railtransportation network. Sumitomo Corporation has long been involved in the development of railway
infrastructure in foreign countries as an EPC contractor that executes all engineering, procurement andconstruction activities. In 2020, it invested in a railway operation and maintenance project in Manila, thePhilippines. The company will expand clean transportation through comprehensive businessdevelopment for railway infrastructure.
④ Provision of base station sharing services
Project Category: Energy efficiency
Project Summary: The proceeds will be allocated to the construction and operation of base stations
that can be used by several mobile network operators. Sumitomo Corporation will provide 5G-centeredbase station sharing services through Sharing Design Inc., a subsidiary jointly invested by Tokyu
Corporation.
Environmental Benefits: Mobile network operators are setting up base stations to provide
communications infrastructure for the rapidly digitalizing society enabled by 5G, a technology offeringhigh-speed, high-capacity, low-latency communications to multiple users simultaneously. Because thestrong straightness of high-frequency 5G waves makes it difficult to ensure communications in anenvironment with many obstacles such as buildings, 5G requires more base stations than 4G and otherprevious networks. In addition, these base stations consume massive power each day to always provide
stable 5G communication services. While mobile network operators have been setting up their own basestations so far, Sumitomo Corporation will install antennas and cables that can be shared by several
mobile network operators, thereby consolidating base station functions to reduce energy consumption.
The provision of base station sharing services will achieve both the spread of efficient 5G networks andenergy savings. The company aims to extend this initiative nationwide from the current coverage
centered on major metropolitan areas.
⑤ Development, construction, renovation and acquisition of energy-efficient properties
Project Category: Energy efficiency
Project Summary: The proceeds will be allocated to the development, construction, etc. of properties
that have received or are expected to receive BELS 5 stars.
Environmental Benefits: BELS stands for Building-Housing Energy-efficiency Labeling System. Thiscertification system is based on the Guidelines for Building Energy Efficiency Labeling developed by the
Ministry of Land, Infrastructure, Transport and Tourism. Based on their primary energy consumption, athird-party organization evaluates the energy efficiency of buildings and ranks their results on a five-starscale. The highest five star ranking is given to buildings with energy efficiency equivalent to ZEBs. CO2
emissions are expected to be reduced through investment in energy-efficient buildings.
⑥ Water supply, sewerage and related businesses
Project Category: Sustainable water and wastewater management
Project Summary: The proceeds will be allocated to water supply and sewerage infrastructuredevelopment and operation businesses in foreign countries.
Environmental Benefits: Due to water shortage and water pollution resulting from population growthand urbanization, there are many countries and regions that lack a hygienic living environment. Amid
increasing demand for water infrastructure that can solve this issue, Sumitomo Corporation is working to

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develop and operate water supply and sewerage facilities in several countries by partnering with local
businesses. Such projects are based on the prerequisite of building sustainable infrastructure inharmony with the natural environment and society. It mitigates risks arising from each stage ofinfrastructure development to operation by complying with relevant laws and regulations in the relevant
country and identifying environmental impacts through environmental assessments. In the water supply
business, the company supplies safe, high-quality water through efficient water intake based on the finite
nature of water resources, while conserving the environment in the basin of a river from which water istaken. The sewerage business helps prevent water pollution and improve hygiene by achieving both
energy savings and treatment capacity enhancement through facility operation optimization.

[Sumitomo Corporation website]⑦ Development, construction, renovation and acquisition of green buildings
Project Category: Green buildings
Project Summary: The proceeds will be allocated to the development, construction, etc. of properties
that have received or are expected to receive one of the following third-party environmental certifications:－LEED: Platinum, Gold
－BREEAM: Outstanding, Excellent－CASBEE Construction (New Construction, Existing Building, Renovation),
CASBEE Real Estate: S rank, A rank
－DBJ Green Building Certification: 5 stars, 4 stars－BCA Green Mark: Platinum, Gold Plus
－HQE: Exceptional, Excellent－DGNB: Platinum, Gold
－Green Star: 6-star, 5-star
Environmental Benefits: Sumitomo Corporation will reduce environmental load by obtaining green
building certifications that prove a property's energy efficiency and implementation of other measures toaddress environmental and social risks. As the company runs its real estate business in and outside

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Japan, target certifications include those from major foreign certification systems, such as Green Mark in
Singapore, HQE in France, DGNB in Germany and Green Star in Australia. These correspond to LEED,BREEAM and other certification systems that are internationally recognized. With the highest or second
highest level in such certification systems being eligible, the company will supply environmentally friendly,
efficient properties and thereby contribute to the conservation of the global environment.
⑧ Telecommunications

businessandfinancialservicesingeographicallyandsocio-economically disadvantaged areas
Project Category: Access to essential services
Target Population: Underserved, owing to a lack of quality access to essential services
Project Summary: The proceeds will be allocated to the construction of telecommunications
infrastructure that contributes to the realization of a more prosperous living environment, as well as to theprovision of financial services that help eliminate poverty, in developing countries, particularly in Africa
and Asia.
Social Outcomes: In Asia and Africa, there are countries and regions where people still do not havesufficient access to mobile telecommunications services and internet services, making bridging the digital
divide a challenge. Ethiopia is one of these countries. Due partly to years of monopoly of thecommunications market by a state-owned company, the country's mobile penetration rate is low
compared to other African countries. Following the Ethiopian government's decision to liberalize thetelecommunications market in 2019, Sumitomo Corporation entered the market by partnering with
Vodafone Group Plc, a leading mobile telecommunications carrier in the U.K., and started to provide
mobile telecommunications services in October 2022. With strength in stable, high-speed
communications services, the business is expanding in major cities, covering around 30% of Ethiopia's
population as of end-September 2023. The company aims to provide almost all Ethiopian people withaccess to the service by 2030. Efforts are also underway to offer digital financial services, which are
rapidly spreading in many countries against the backdrop of the development of mobile communications
infrastructure. In developing countries, where many people, especially those in poverty, are unable toopen a bank account, mobile money based on mobile phone short message service (SMS) or otherplatforms is popular as a tool for making payments. Sumitomo Corporation invests in M-KOPA holdings
Limited, a provider of Pay-As-You-Go asset finance for the purchase of smartphones and other products
using mobile money. Such services are growing in African countries, particularly among low and notstable income population, allowing people to buy products in small daily payments. The company will
accelerate the creation of the circumstance where everyone can receive financial services equally, inorder to achieve financial inclusiveness in developing countries.

(3) Consideration for Negative Environmental and Social Impacts


Sumitomo Corporation has established a companywide framework to perform appropriate monitoring of
the environmental and social impact of the Group's entire business activities. At the time of investment
application, risks are identified in terms of the nature and regional characteristics of each business, andthe Corporate Sustainability Department participates in discussions at the Company Investment
Committee to make risk management more effective. As follow-up to the investment, the company holds
dialogue with group companies to carry out regular monitoring from the viewpoint of the environment,
human rights, labor management, the supply chain and other aspects, and internal audits are also used
to conduct appropriate risk management.

If, as a result of this process of review and monitoring of investments, an important environmental orsocial risk is confirmed, the individual response is reported or referred for further discussion to theManagement Council and the Board of Directors. The company is striving to strengthen its risk
management framework under the supervision of the Board of Directors.

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The proceeds will be allocated to green projects and social projects. The eligibility criteria is clearly definedwith corresponding project categories illustrated in the ICMA and other principles, and clear environmental
benefits and social outcomes are expected. Green eligible projects include the renewable energy generation
business, the battery storage business, the forest management business, the operation and maintenance ofurban passenger railways, base station sharing services, the development and acquisition of energy-efficient
properties, the development and operation of water infrastructure, and the development and acquisition ofgreen buildings. Social eligible projects are the telecommunications business and financial services in
geographically and socio-economically disadvantaged areas, targeting those underserved owing to a lack ofquality access to essential services. These initiatives are designed to bridge the digital divide and achievefinancial inclusiveness. With the companywide risk management framework in place, negative environmental
and social impacts from project implementation are managed appropriately. The use of proceeds isreasonable.

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2. Process for Project Evaluation and Selection(1) Incorporation into Comprehensive Objectives, Strategies and so onSumitomo Corporation established Sumitomo Corporation Group's Management Principles based on
Sumitomo's Business Philosophy and formulated the Activity Guidelines to realize the Management
Principles. "Benefit for self and others, private and public interests are one and the same," which refers to
the idea that Sumitomo's business, while benefiting Sumitomo, must also benefit the nation and benefit
society, is one of the credos that are contained in Sumitomo's Business Philosophy and represents thecorporate vision that the Sumitomo Corporation Group as a whole must pursue at all times. By sharing
the values presented in the Management Principles and the Activity Guidelines across the Group tomaterialize them in specific business activities, the Group aims to be a global organization that constantly
creates new value and contributes to society.

[Sumitomo Corporation website]

Sumitomo Corporation identified Six Material Issues to Achieve Sustainable Growth with Society aspriority issues to be addressed through its business activities by leveraging its strengths. To secure its
growth and address social issues simultaneously and maintain and enhance its management style andcorporate culture as a prerequisite for this, the company works on Achieving Harmony with the Global
Environment, Contributing to the Development of Local Communities and Industries, Establishing aFoundation for Comfortable and Enriching Lifestyles, Providing Diverse "Accessibility," Developing
Human Resources and Promoting Diversity, and Enhancing Governance.

To enhance sustainability management, the company identified six key social issues under two themes:"sustainability of society" and "development and evolution of society." It set out medium- and long-termtargets to address each of the key social issues of "Mitigation of climate change," "Circular economy,""Respect for human rights," "Development of local society and economy," "Improvement of living
standard" and "Quality education," clarifying the Group's role in realizing a sustainable society.

The eligible projects in the Framework are consistent with the Group's material issues and key social
issues, and positioned as initiatives to practice the Management Principles.

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Second Opinion(2) Criteria for Project Evaluation and SelectionThe eligibility criteria sets out initiatives that are in line with the Management Principles and addressmaterial issues and key social issues. They correspond to the project categories of Renewable energy,
Environmentally sustainable management of living natural resources and land use, Clean transportation,
Energy efficiency, Sustainable water and wastewater management, Green buildings, and Access toessential services.



In project evaluation and selection, eligibility is determined after being discussed from the perspective ofenvironmental and social risk management under the risk management framework mentioned above.

(3) Process for Project Evaluation and Selection

The Finance Department, with the cooperation of the Corporate Sustainability Department, selects
projects that meet the eligibility criteria. The final decision is made by the Chief Financial Officer.

Eligible projects are consistent with the Sumitomo Corporation Group's material issues and key social issues,and the finance under the Framework is positioned as that aimed at practicing the Management Principles. A
process is in place where the Finance Department, with the cooperation of the Corporate Sustainability
Department, selects projects and the final decision is made by the Chief Financial Officer. The involvement of
the department with ESG expertise enables the comprehensive examination of effects and risks of projects.
The process for project evaluation and selection is clear and rational.

3. Management of Proceeds


The Finance Department will track and monitor the proceeds so that the same amount of funds raised
will be allocated to eligible projects.

The proceeds will be allocated to eligible projects generally within three years. Any unallocated funds
generated from the sale of assets or other events will be reallocated to other projects that meet theeligibility criteria. The unallocated funds will be managed in cash or cash equivalents.

The Finance Department will track and monitor the proceeds. Any unallocated funds generated from the saleof assets or other events will be reallocated to other eligibility projects. The unallocated funds will be managedin cash or cash equivalents. The management of proceeds is appropriate.

4. Reporting(1) Overview of DisclosureReporting will be made as shown below within around one year after funds are raised. If there is any
significant change in allocation status, Sumitomo Corporation will disclose it on the company's website
even after the full amount of the proceeds has been allocated.

Disclosure Items & Example Indicators

MethodAllocation ofProceeds

・The amount and status of allocation in each business category
・The amount, planned timing of allocation, and investment method of
unallocated funds (disclosed on an annual basis)

WebsiteEnvironmental
Benefits &SocialOutcomes

See "Indicators to Show Environmental Benefits and Social Outcomes" inthe next section.

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Second Opinion(2) Indicators to Show Environmental Benefits and Social Outcomes

Sumitomo Corporation will disclose the following impact reporting to indicate environmental benefits andsocial outcomes.

＜Green Eligible Projects＞
Project Category
Renewable energy

Eligibility Criteria
 Wind power generation
 Solar power generation
 Geothermal power generation
 Battery storage business with gridstability

Reporting Items
 Annual reduction in CO2emissions (t-CO2)
 Power generation capacity(MW)

Environmentally
sustainable
Acquisition, utilization and maintenancemanagement of living
Forest area acquiredof forest assets
natural resources andland use
Clean transportation

Energy efficiency

Operation and maintenance of urban
passenger railways

 Number of stations
 Route length (km)Base station construction and operation
Case study on 5G base stationnecessary for providing base station
installation
sharing services
Development, construction, renovation,acquisition, etc. of properties which
Level of BELS rating
have received or are expected to receive
BELS 5 stars

Sustainable water
and wastewater
management

 Water supply Sewerage management
 Related equipment and pipes

Green buildings

Development, construction, renovation
and acquisition of properties which haveType and level of certification
received or are expected to receive agreen building certification

Water management capacity(m3)＜Social Eligible Projects＞
Project
Category

Eligibility Criteria

Example Reporting Items
OutputOutcome

Telecommunications
 Population coveragebusiness with
Project
 Number of base stations
solution of digital
overview
 Number of subscribers
divideAccesstoessential
 Number of customers,
Financial services toservices
Project
service coverage ratio
enhance financial
overview  Amount of financial
resilience/stability
service (credit amount)ImpactEconomic growth andsocial progress withsolution of digital divide Enhanced financial
resilience/stability
 Expansion of financial
accessibility for
low-income population

Sumitomo Corporation will disclose the allocation of proceeds, environmental benefits and social outcomes
within around one year after the funds are raised. Environmental benefits will be disclosed mainly using
quantitative indicators, and social outcomes will be reported in terms of output, outcome and impact. The
reporting is appropriate.

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