Summit Pharmaceuticals International Corporation
Modern Slavery and Human Trafficking Statement for the Fiscal Year 2021

Summit Pharmaceuticals International Corporation（SPI） is committed to improving
its practices to combat modern slavery and human trafficking. This statement has been
published in accordance with the UK Modern Slavery Act 2015 and constitutes SPI’s
modern slavery and human trafficking statement for the fiscal year 2021 ended March31, 2022. This statement was approved by the board of directors of SPI on June 28, 2022.

The organisation’s structure, its business and its supply chains
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 the company’s business overview, please visit the following
link :
https://www.summitpharma.co.jp/english/

Steps taken to ensure that modern slavery and human 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
and represents SC Group's fundamental and ultimate value standard. In the Corporate
Mission Statement, it clearly states that SC Group respects the personality of eachindividual and places prime importance on integrity and sound management.
The company takes its commitment to tackling modern slavery and human trafficking
very seriously. We set out below the steps we have taken to help ensure that modern
slavery and human trafficking are not taking place in our business or supply chains:

1The SC Group’s Human Rights Policy
The company respects “the International Bill of Human Rights” and the International
Labor Organization’s “Declaration on Fundamental Principles and Rights at Work”, andwe operate in accordance with “the United Nations Guiding Principles on Business andHuman Rights”.
The company, also as a member of the SC Group, in line with the SC Group’s Human
Rights Policy, i) we strive to identify and to prevent or mitigate any adverse impact onhuman rights through the implementation of human rights due diligence processes, ii)
where we identify that our group’s practices have caused or contributed to an adverse
impact on human rights, we will endeavor to take appropriate remedial measures, iii) wewill seek to improve and progress human rights measures through engagement anddialogue with relevant stakeholders, and so on.
The SC Group’s CSR Action Guidelines for Supply Chain Management
The company acts in accordance with the SC Group CSR Action Guidelines for Supply
Chain Management. Through the implementation of these guidelines, we are aiming torealize a sustainable society by working together with our suppliers, business partners
and contractors, etc. to achieve responsible value chain management. As part of theseguidelines, we set out its values to “Respect for human rights and not to be complicit inhuman rights abuses” and to “Prevent forced labor, child labor and the payment ofunfairly low wages.” These principles establish the overarching guidelines
encompassing our commitment to combating modern slavery and human trafficking.
In the event that we find violations of these guidelines in our supply chains, we will urge
the suppliers, business partners or contractors, etc. to remedy and improve the situation,
while providing support to them as needed. However, if there are no improvements tothe situation by them, we will consider carefully whether to continue our business withthem or not.
Enhancement of SC Group Governance
As a member of the SC Group, the company is collaborating with SC on “Enhancementof SC Group Governance” aiming to improve business quality and corporate value
through internal control. Specifically, we have introduced a governance framework thatuses SC Group’s standard tool called Basic Elements to visualize the internal control
status of each group company and solve issues identified through “dialogue” with theparent company.
The Basic Elements include “Respect for Human Rights”, “Labor Management, Health,Safety and the Environment”, and “Supplier Management”, and if there are issues, weformulate a response policy according to its business nature and regional conditions.
Through regular monitoring, we will continue working to prevent modern slavery andhuman trafficking in our business or supply chains through further enhancing
governance considering its business nature and regional conditions.

2Training
In order to raise our awareness especially about modern slavery, the company utilizes anAmerican NGO Verite's free e-Learning of Supply Chain Accountability on forced laboras a useful training material, which is one of the referred tools on 'Transparency inSupply Chains: A Practical guide' published by UK Home Office.
The company believes that eradication of modern slavery is important, and we willcontinue to undertake these efforts aimed at ensuring that no modern slavery or humantrafficking of any form exists in our business and supply chains.

June 30, 2022

Signed by:
Katsuya Okuyama
President & CEO
Summit Pharmaceuticals International Corporation3