Summit Pharmaceuticals International Corporation
Modern Slavery Act Transparency Statement for FY 2023

Summit Pharmaceuticals International Corporation (SPI) is committed to improving its
practices to prevent modern slavery including forced labour, child labour and humantrafficking. This statement addresses the fiscal year 2023 (from April 1, 2023 to March 31,2024), in compliance with the requirements of Modern Slavery Act 2015 of the UK. This
statement was approved by the board of directors of SPI on June 26, 2024.

Background and organisational structure

We have 4 bases in Japan and 2 subsidiaries overseas. Our business are as follows.
1. Import, export and sale of pharmaceuticals, quasi-drugs, medical devices, foodadditives, as well as their raw materials, bulk, final products.
2. Import and sale of cells of animal and plant, microorganism and human tissue samples
as drug discovery tools and research instruments, and arrangement of researchcollaboration.
3. Consultancy of drug development and support of new drug licensing.
For more information on SPI’s business overview, please visit the following link :https://www.summitpharma.co.jp/english/
Steps taken to ensure that modern slavery including forced labour, child labour andhuman trafficking are not taking place in SPI’s business and supply chains
SPI, as a member of the Sumitomo Corporation (SC) Group, shares Sumitomo's Business
Philosophy, which has been passed down and followed faithfully for more than 400 years
since Masatomo Sumitomo (1585-1652) had founded. SC Group’s Corporate Mission
Statement (Management Principles and Activity Guidelines) is based on this philosophy andrepresents SC Group’s fundamental and ultimate value standard. In the Corporate Mission
Statement, it clearly states that SC Group respects the personality of each individual andplaces prime importance on integrity and sound management.
Furthermore, to achieve sustainable growth through resolving social issues, we have set"Respect human rights" as one of "Material Issues" which are referred to important social
issues that SC Group must address and its advanced medium- to long-term commitments
toward resolving them. We will continue to promote these efforts and disclose our progress.
SPI takes its commitment to tackling modern slavery including forced labour, child labourand human trafficking very seriously. The followings are the steps which we have taken to1

help ensure that modern slavery including forced labour, child labour and human trafficking
are not taking place in our business or supply chains:

SC Group’s Human Rights Policy
SPI respects the International Bill of Human Rights and the International Labour
Organization (ILO)’s Declaration on Fundamental Principles and Rights at Work, and weoperate in accordance with the United Nations (UN) Guiding Principles on Business andHuman Rights.
SPI also acts, as a member of the SC Group, in line with SC Group’s Human Rights Policy,i) we strive to identify and to prevent or mitigate any adverse impact on human rights throughthe implementation of human rights due diligence processes, ii) where we identify that ourgroup’s practices have caused or contributed to an adverse impact on human rights, we will
endeavour to take appropriate remedial measures, iii) we will seek to improve and progresshuman rights measures through engagement and dialogue with relevant stakeholders, and soon.

The SC Group CSR Action Guidelines for Supply Chain Management
SPI acts in accordance with the SC Group CSR Action Guidelines for Supply ChainManagement. Through the implementation of these guidelines, we are aiming to realize asustainable society by working together with our suppliers, business partners and contractors,etc. to achieve responsible value chain management. As part of these guidelines, we set out
its values to “Respect for human rights and not to be complicit in human rights abuses” andto “Prevent forced labour, child labour and the payment of unfairly low wages.” These
principles establish the overarching guidelines encompassing our commitment to preventing
modern slavery including forced labour, child labour and human trafficking.
In the event that we find violations of these guidelines in our supply chains, we will urge thesuppliers, business partners or contractors, etc. to remedy and improve the situation, whileproviding support to them as needed. However, if there are no improvements to the situationby them, we will consider carefully whether to continue our business with them or not.

Group Governance
As a member of the SC Group, SPI is operating an optimal management system to control
risks appropriately and increase the odds of achieving its business strategies for management.
Specifically, we have introduced a governance framework that uses SC Group standard tool
called Basic Elements to visualize the internal control status and solve issues identified
through “dialogue” with SC.
The Basic Elements include “Respect for Human Rights”, “Response to workplace
accidents”, “Labour Management, Health, Safety and the Environment”, and “SupplierManagement”, and if there are issues, we formulate a response policy according to its
business nature and regional conditions. Through regular monitoring, we will continue
working to prevent modern slavery including forced labour, child labour and humantrafficking in our business or supply chains through further enhancing governanceconsidering its business nature and regional conditions.

2Training
In order to raise our awareness especially about modern slavery, SPI utilizes an American
NGO Verite's free e-Learning of Supply Chain Accountability on forced labor as a usefultraining material, which is one of the referred tools on 'Transparency in Supply Chains: A
Practical guide' published by UK Home Office.

SPI believes that eradication of modern slavery is important, and we will continue toundertake these efforts aimed at ensuring that no modern slavery or human trafficking of any
form exists in our business and supply chains.

June 26, 2024

Signed by:

Katsuya Okuyama
President & CEO
Summit Pharmaceuticals International Corporation3