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Sumitomo Electric Group
SUPPLIER
CODE OF CONDUCT1

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Table of Contents
Commitment to-We Expect Compliance with Anti-Corruption Laws
Compliance with the Law -We Expect Compliance with Competition Laws
-We Expect Protection of SEG’s Intellectual Property-We Expect Compliance with International Trade Laws
Commitment toResponsible Sourcing-Engagement with Supply Chain-Conflict Minerals-Responsible and Sustainable Sourcing Practices

Commitment to People-We Expect Compliance with Employment Laws
-We Oppose the Use of Forced Labor-We Oppose the Use of Child Labor-We Oppose any Form of Human Trafficking-We Oppose Harassment-We Oppose Discrimination and Encourage Diversity-We Respect Workers’ Rights of Association-We are Committed to Safe Work Environments-We Expect that Personal Data will be Protected

Commitment to Society-We are Committed to Protecting the Environment-We are Committed to Advancing the Communities Where We Operate

Commitment to-We Expect Suppliers to Provide Employees with a Means to ReportCompliance and Business Concerns
Ethics-We Expect Suppliers to Maintain Accurate Business Information-We Expect Suppliers to Adopt Appropriate Compliance and Ethics
Initiatives
Issues Related to thisCode（SEG Hotline）（Audit/review/request of information）（Contacts）

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The Sumitomo Spirit
Banji-nissei – Do your sincere best, not only in business but in every aspect of your life.
Shinyo-kakujitsu – Place importance on integrity and good management.
Fusu-furi – Never sacrifice integrity for easy profits.

Sumitomo Electric Group
Supplier Code of Conduct
For more than 120 years, the Sumitomo Electric Group (“SEG”) has been guided by the SumitomoSpirit, with its emphasis on integrity and business ethics. SEG seeks to contribute to society
through fair and sustainable business activities, and to do business with suppliers who share its
commitment to integrity and business ethics.
This Supplier Code of Conduct (“Code”) sets out SEG’s expectations of our suppliers, which
includes suppliers, subcontractors, agents, consultants, distributors or any other party that receives
payments from SEG for its products or services.
At SEG, we recognize that our suppliers play an important role in our overall success. We
appreciate the contributions that our suppliers make to our business. We choose to do businesswith suppliers that share our commitment to integrity and to conducting business in compliancewith the law. SEG asks that our suppliers conduct business in a manner that is consistent with theprinciples set out below and that they cascade similar expectations throughout their own supplychains.

Commitment to Compliance with the Law
SEG expects our suppliers to conduct their business activities in compliance with all applicablelaws and regulations.
We Expect Compliance with Anti-Corruption Laws
Bribery causes enormous harm to communities, and it can cause significant damage to SEG. SEG
expects our suppliers to comply with all applicable anti-corruption laws. In addition, when asupplier interacts with a government official on behalf of SEG, the supplier is absolutely prohibitedfrom offering, giving, or receiving anything of value, directly or indirectly, to obtain an improper
business advantage.
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We Expect Compliance with Competition Laws
SEG is committed to compliance with competition and antitrust laws, and we expect a similar levelof commitment from our suppliers.
We Expect Protection of SEG’s Intellectual Property
SEG expects our suppliers to protect any SEG intellectual property that is obtained during thecourse of our relationship.
We Expect Compliance with International Trade Laws
SEG is proud to be a global company and to have suppliers located around the world. We expect
our suppliers to respect applicable import and export laws and regulations and other international
trade requirements.

Commitment to Responsible Sourcing
Engagement with Supply Chain
Sustainable management of supply chains is of growing importance to our stakeholders, including
customers and investors. We have set social and environmental requirements for our suppliers formany years. We will continue our cooperation with suppliers, and we will increase ourengagements in strategic areas, all to improve sustainable capabilities in the supply chain.
Conflict Minerals
In particular, SEG requires our suppliers to take appropriate steps to determine if their products
contain conflict minerals (tin, tantalum, tungsten, and gold) and, if so, to implement processes toidentify the sources of these minerals and otherwise comply with all applicable laws andregulations governing the sourcing and use of conflict minerals. We expect suppliers to eliminate
the use of conflict minerals that – directly or indirectly – finance or benefit armed groups in theDemocratic Republic of Congo (the “DRC”) and adjoining countries.
Responsible and Sustainable Sourcing Practices
The DRC is also the world’s largest producer of cobalt. Cobalt extraction raises similar concerns
to conflict minerals and has also become a concern.
We encourage our suppliers to use responsible and sustainable practices to source all raw materials,
including cobalt and other minerals. We encourage all suppliers to take into account evolving
international standards and developments regarding environmental issues, human rights, and othersocial problems, particularly in conflict-affected and high-risk areas.

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Commitment to People
SEG is committed to respecting human rights. Our commitment includes identifying, preventingand mitigating adverse human rights impacts of our activities. We expect our suppliers to sharethe same respect for human rights, including a commitment to generally recognised international
human rights standards.
We Expect Compliance with Employment Laws
SEG expects our suppliers to comply with all applicable laws regulating work hours, wages,
benefits and other terms and conditions of employment, including employment contracts, ifapplicable.
We Oppose the Use of Forced Labor
SEG will not work with suppliers who – directly or indirectly – use slave labor, or any other formof forced, coerced or involuntary labor in their workforce. Suppliers should never ask employees
or any member of their workforce to surrender their passports, government-issued identifications,or work permits as a condition of employment.
We Oppose the Use of Child Labor
SEG will not work with suppliers who – directly or indirectly – use illegal child labor in carryingout their business. For these purposes, “child” refers to anyone under the minimum legal age foremployment where the work is performed, but in any event SEG will not work with suppliers
whose direct or indirect workforces include children under the age of 15 years.
We Oppose any Form of Human Trafficking
SEG will not work with suppliers who directly or indirectly engage in the trafficking of people.
We Oppose Harassment
SEG expects our suppliers to treat their workforce with the dignity and respect to which all humanbeings are entitled. Suppliers should create a work environment that does not tolerate harassment
or other abusive conduct toward employees.
We Oppose Discrimination and Encourage Diversity
SEG expects our suppliers to provide equal employment opportunities to employees and applicantsfor employment without unlawful discrimination based on race, ethnicity, national origin, religion,age, gender, gender identity, sexual orientation, disability, or any other characteristic protected byapplicable laws.
SEG encourages its suppliers to promote diversity and to foster an inclusive and ethical culture
within its workplace.
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We Respect Workers’ Rights of Association
SEG expects our suppliers to respect the rights of workers to associate or not to associate inaccordance with applicable law.
We are Committed to Safe Work Environments
SEG expects our suppliers to protect the health, safety and welfare of their people, visitors, andothers who may be affected by their activities. Suppliers must comply with all applicable
workplace health and safety laws and regulations.
We Expect that Personal Data will be Protected
SEG expects our suppliers to observe all applicable laws that require the protection of the personal
data of employees, customers and other parties. In addition, suppliers must promptly notify SEGof any breach of data privacy law by a supplier or any party that the supplier does business withthat affects SEG.

Commitment to Society
We are Committed to Protecting the Environment
SEG is committed to environmental stewardship and to reducing the environmental impact of ouractivities. We expect our suppliers likewise to reduce the environmental impact of their business
operations, to manage the risks of environmental harm, and to comply with all applicable
environmental laws and regulations. SEG encourages its suppliers to pay particularly close
attention to: the reduction of greenhouse gases, increasing energy efficiency, the use of renewables,
the efficient use of energy, water and raw materials, and the adoption of sustainable resourcesmanagement and waste reduction processes.
We are Committed to Advancing the Communities Where We Operate
One of SEG’s corporate principles is that we contribute to creating a better society andenvironment, with a firm awareness of our social responsibility. We expect a similar commitment
from our suppliers.

Commitment to Compliance and Business Ethics
We Expect Suppliers to Provide Employees with a Means to Report Concerns
SEG expects its suppliers to provide employees with avenues for raising suspected violations oflaw or other concerns without fear of retaliation. We further expect that suppliers will respond toconcerns appropriately.

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We Expect Suppliers to Maintain Accurate Business Information
We expect suppliers to complete all business documents (including quality documents) accurately,truthfully, and in a timely manner. We also expect our suppliers to make full, fair, accurate, andtimely disclosures in reports and documents filed with government regulators, including any
periodic financial reports. We expect that, when applicable, suppliers’ documents must be
properly authorized. In addition, we expect that any recording of suppliers’ financial activities bein compliance with applicable laws and accounting practices. Suppliers must not make false or
misleading entries in their documents and records and never omit information from their records
that they are required to record.
We Expect Suppliers to Adopt Appropriate Compliance and Ethics Initiatives
To the extent possible and in a manner that is commensurate with the size and nature of theirbusinesses, SEG expects suppliers to adopt effective compliance and ethics programs of their own.
SEG encourages its suppliers to implement their own codes of conduct and to foster a culture ofcompliance and business ethics in their organizations, including avoiding conflicts of interest.

Issues Related to this CodeSuppliers (or their employees) may inform SEG of concerns related to issues governed by thisCode. If there are any concerns under this Code, we encourage you to reach out to your primarybusiness contact.
If that is not appropriate, please contact the hotline athttps://sumitomoelectric.com/compliance-hotlines.
SEG reserves the right to conduct an audit/review of the supplier to ensure conformity to this Code.
Because SEG seeks to do business with suppliers who share our commitment to compliance withlaw and ethical, responsible business practices, we will review the terms of our business
relationships if we become aware that a supplier has violated the law or failed to comply with thisCode. To this end, SEG may request information related to our suppliers’ compliance with thisCode.
If you have questions about this Code, please feel free to contact scoc-queries@info.sei.co.jp.

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