Sumitomo Corporation Group
Slavery and Human Trafficking Statement for the Fiscal Year 2020

Sumitomo Corporation (SC) Group is committed to improving its practices to combat
modern slavery and human trafficking. This statement has been published in accordancewith the UK Modern Slavery Act 2015 and constitutes SC Group’s modern slavery andhuman trafficking statement for the fiscal year 2020 ended March 31, 2021. Thestatement has been approved by the board of directors of SC as the parent company ofSC Group every year. This statement was approved by the board of directors of SC on
August 30, 2021.

Background and organisational structure
SC Group is an integrated corporate group committed to business activities in a wide
range of industries with over 130 offices and subsidiaries in over 60 countries and anetwork of over 900 group companies worldwide. With its global network and based ontrust from companies in various industries and from consumers, SC Group engages in
multifaceted business activities by making the most of its integrated corporate strength.
These business activities include sales of a variety of products and services within Japan,
import and export, trilateral trade, and domestic and international business investments.
SC Group employs over 70,000 people.
For more information on SC Group’s business overview, please visit the following link:
https://www.sumitomocorp.com/en/jp/about

Steps taken to ensure that modern slavery and human trafficking are not taking
place in SC Group’s business and supply chains
At the core of SC Group lies Sumitomo's Business Philosophy, which has been passed
down and followed faithfully for more than 400 years since Masatomo Sumitomo (15851652) had founded. Our Corporate Mission Statement (Management Principles andActivity 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 SCGroup respects the personality of each individual and places prime importance onintegrity and sound management.
We also identified our “Six Material Issues to Achieve Sustainable Growth with Society”
in 2017, a set of social issues that SC Group regards as important and should prioritize
addressing through its business activities as well as the challenges SC Group needs to1

overcome in creating solutions. SC Group positions these material issues as an importantfactor in developing business strategies and in the decision-making process forindividual businesses.
To enhance our sustainability management, we have identified our “Six Key SocialIssues and the Long-term Goals” in 2020. The six key social issues are related to ourbusiness that we address through our business and corporate activities and consist of twothemes: the sustainability of society and development and evolution of society. As oneof the six key social issues, we have set "respect for human rights" and "to respect humanrights through all of our businesses and supply chains" as its long-term goals.
In addition to the long-term goals, we will further determine medium-term targets andKPIs, which will guide us in addressing these social issues in a quantifiable way. In theinterest of accountability, our progress will be monitored and disclosed to its
stakeholders.
SC Group takes its commitment to tackling modern slavery and human trafficking very
seriously. We set out below the steps SC Group has taken to help ensure that modern
slavery and human trafficking are not taking place in SC Group’s business or supply
chains:SC Group’s Human Rights Policy
We respect “the International Bill of Human Rights” and the International Labor
Organization’s “Declaration on Fundamental Principles and Rights at Work”, and weoperate in accordance with “the United Nations Guiding Principles on Business andHuman Rights”.
In line with SC Group’s Human Rights Policy, i) we strive to identify and to prevent ormitigate any adverse impact on human rights through the implementation of humanrights due diligence processes, ii) where we identify that our group’s practices havecaused or contributed to an adverse impact on human rights, we will endeavor to takeappropriate remedial measures, iii) we will seek to improve and progress human rights
measures through engagement and dialogue with relevant stakeholders, and so on.
Human Rights Due Diligence
In accordance with the SC Group Human Rights Policy, we began human rights due
diligence in 2020 so that we can identify, prevent, mitigate and account for how weaddress any adverse human rights impact that SC Group business activities may cause
or contribute to.
Our human rights due diligence is conducted through a process in accordance withinternational guidelines including the United Nations Guiding Principles on Businessand Human Rights, United Nations Guiding Principles Reporting Framework, andOECD Due Diligence Guidance for Responsible Business Conduct. As a first step in2020, we identified eights salient human rights issues that should be addressed withpriority so that we can assess impacts concerning human rights throughout SC Group,2

by the desktop survey, interviews of experts on business and human rights and internalinterviews.
Identified eight salient human rights issues are as follows；
Labor conditions (wages and working hours), Freedom of association and the right tocollective bargaining, Forced labor and child labor, Occupational health and safety,
Health and safety of local residents, Land rights, Discrimination and harassment, andPersonal information and privacy.
We believe that the human rights of workers throughout the supply chain including SC
Group employees are essential as the foundations of business. In addition to the freedomof association and collective bargaining rights, forced labor and child labor, anddiscrimination and harassment, which are related to the four core labor standards of theInternational Labour Organization (ILO), we also take action to address labor conditions
and occupational health and safety. SC Group engages in business with strong ties inlocal communities centered on the infrastructure business and resource development,
and we have a responsibility to protect the health and safety of local residents and land
rights. Moreover, since SC Group engages in wide-ranging business, we have positioned
the personal information and privacy of stakeholders including customers as priorityissues.
For each of these issues, we will investigate and carry out action plans to prevent andmitigate specific risks with priority on areas of high risk in SC Group’s business.
SC Group’s CSR Action Guidelines for Supply Chain Management
We have established the SC Group CSR Action Guidelines for Supply ChainManagement. Through the implementation of these guidelines, we are aiming to realize
a sustainable society by working together with our suppliers, business partners andcontractors, 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 GovernanceIn order to embody “Management base SHIFT” in the Medium-Term Management Plan
SHIFT 2023, we are working on “Enhancement of SC Group Governance” aiming toimprove business quality and corporate value through internal control for all3

consolidated subsidiaries. Specifically, we have introduced a governance framework thatuses SC Group standard tool called Basic Elements to visualize the internal control statusof each group company and solve issues identified through “dialogue” with the parent
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 SC Group’s business or supply chains through further enhancing
governance considering its business nature and regional conditions.

Social and Environmental Risk Management in Individual Project
In order to promote social and environmental risk management for each business, taking
into account the nature of the business and the characteristics of the region where itoperates, we established a management system that considers social and environmental
impacts when making decision on a new investment, by utilizing an assessment sheet
for social and environmental risks, and by having the Corporate Sustainability
Department, a specialized organization for social and environmental issues, participate
in the process of deliberations.
After the implementation of each investment, we monitor the status of social andenvironmental risk management and if any issues arise, we will work for improvements
according to the characteristics of the business.
Active commitment to the UN Global Compact
We signed the UN Global Compact and declared its support for the 10 principles inMarch 2009 as the parent company of SC Group. This international sustainability related
initiative shares the same values as our Corporate Mission Statement. With ourparticipation in the Global Compact, we have committed ourselves to further increasing
corporate value by constantly seeking out areas of our business activities that can be
improved in light of the values advocated by the 10 principles. The UN Global Compact
has been referred also through the internal auditing process of SC Group.
Training
In order to raise our awareness especially about modern slavery, we have utilized anAmerican NGO Verite's free e-Learning of Supply Chain Accountability on forced laborand human trafficking as a useful training material, which is one of the referred tools on'Transparency in Supply Chains: A Practical guide' published by UK Home Office.
Since SC Group conducts a wide range of business in multiple sectors, the associatedrisks vary, however the eradication of any instances of modern slavery and humantrafficking remains a key priority.

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We will continue to undertake these efforts aimed at ensuring that no modern slavery or
human trafficking of any form exists in our business and supply chains.

September 27, 2021

Hideki Yamano
Representative Director,Senior Managing Executive Officer,
Chief Strategy Officer and Chief Information Officer
Sumitomo Corporation

Katsuya Okuyama
President & CEO
Summit Pharmaceuticals International
Officer Corporation

This statement covers the following consolidated subsidiaries, and please refer to theappendix for each company’s initiatives;- Edgen Group Inc.
- Edgen Murray Europe Ltd.
- Eryngium Ltd.
- Fyffes Group Ltd.
- Fyffes Ltd.
- Fyffes Tropical (Ireland) Ltd.
- Howco Group Plc- Kienle + Spiess GmbH
- Moto-Pfohe Eood- Pacific Summit Energy LLC- SC Foods Co., Ltd.
- Sumi Agro Europe Ltd.
- Sumi Agro Ltd.
- Sumisho Aero-Systems Corporation- Sumisho Global Logistics Co., Ltd.
- Sumitomo Corporation Power & Mobility Co., Ltd.
- Sumitomo Corporation Asia & Oceania Pte. Ltd.
- Sumitomo Corporation Europe Ltd.
- Sumitomo Corporation Global Commodities Ltd- Sumitomo Corporation Middle East FZE- Sumitomo Corporation of Americas- Sumitomo Corporation Saudi Arabia Ltd.
- Sumitomo Corporation (Shanghai) Ltd.
- Sumitomo Deutschland GmbH
- Sumitomo Shoji Chemicals Co., Ltd.

5- Summit Agro International Ltd.
- Summit Exploration and Production Ltd.
- Summit Energy & Resources Pte. Ltd.
- Summit Motors Ljubljana, Export-Import-Distribucija, D.O.O.
- Summit Motors Slovakia, Spol.S.R.O.
- Summit Pharmaceuticals Europe Srl.
- Summit Pharmaceuticals International Corporation- Tecnologia Para la Construccion Y Mineria S.L.

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