JFE Steel Procurement Guidelines

JFE Steel has established these JFE Steel erocurement Guidelines in accordance with the JFE Group
Standards of Conduct and the JFE Group Basic eolicy on Human Rights, aiming to enhancesustainability across its entire supply chain.
We share these guidelines with our business partners and promote sustainability initiatives
throughout our supply chain. In addition to asking all business partners to implement theguidelines, we also ask that partners' own suppliers be encouraged to do the same.
JFE Steel is committed to maintaining and improving mutual understanding and trust with its
business partners as part of pursuing mutual development as a true business partner.

1. Compliance
Compliance with Applicable Laws and Regulations• We comply with all relevant laws, regulations, and social norms in countries and regions where
we operate our business. We also respect treaties, agreements and other international rules in ourinternational transactions.
• We develop and implement policies, systems, codes of conduct, education, and otherframeworks to ensure thorough compliance.
Management of personal and confidential information
We properly manage and protect all personal information of all parties involved in our business,
including suppliers, customers and employees, as well as confidential information obtained throughtransactions and other business.
Cyber security
We implement cyber security measures and manage our systems to prevent damage to ourcompany and other parties.
Anti-Corruption
We do not participate in bribery of government officials, other public servants, or business
partners, and we strive to prevent corruption and maintain fair business practices.
Avoidance of Organized crime
We refuse to have any relationship with criminals or groups that threaten civil order and safety,
and we do not respond to illegal or unreasonable demands.
Fair competition• We comply with all laws and regulations of countries and regions where we operate our business,
and we do not engage in practices such as private monopoly, unfair restrictions on trade (cartels,bid rigging, etc.), unfair trade practices, or abuse of superior bargaining positions.
•When selecting suppliers, we base our decisions on economic rationality as well as suppliers’
thorough implementation of appropriate quality-control and quality assurance covering not onlyquality but also technology, price, delivery time, supply stability, reliability, business stability andcommitment to CSR（corporate social responsibility）.

Intellectual property (IP) policy
We take all necessary steps to protect our own Ie rights. In addition, we respect the Ie rights
owned by other parties and do not unlawfully obtain, use nor infringe such rights.
Quality assurance• We comply with all applicable laws and regulations regarding the quality of our products andservices as well as observe our own quality standards and the requirements of customers.
• We establish and operate quality-management systems that ensure high and stable quality.

2. Respect for Human Rights
JFE Steel is committed to implementing JFE Group’s Human Rights Basic eolicy, as outlinedhereafter.
Prohibition of Child labor
To avoid hindering children’s development and educational opportunities, we do not employ
children under the minimum working age stipulated by the laws and regulations of counties andregions where we operate our business.
Prohibition of Forced labor• We do not use labor obtained through inhumane means, such as forced labor, human trafficking,or "modern slavery." Also, we do not engage in any dealings that promote such inhumane acts.
• We do not force anyone to perform labor against their will. We do not retain employees’
passports, official identification, or work permits as a condition of employment. We also do not
require employees to pay recruitment fees or any other costs considered unreasonable underinternational norms.
Prohibition of Discrimination and harassment
We respect each person as an individual in all aspects of corporate activity and do not discriminate
on the basis of race, nationality, ethnicity, creed, religion, social status, family origin, age, gender,sexual orientation, gender identity, disability or for any other reason. We also do not engage in any
other form of harassment, including language or behavior that offends a person's dignity or causes
them discomfort.

Rights of indigenous and local peoples
We respect and give due consideration to local people's land rights, water access, safety, andhealth as well as the rights of indigenous peoples in areas where we operate.
Occupational health and safety
Based on our policy of prioritizing safety above all else, we strive to prevent work-related accidents
and illnesses as well as consistently maintain safe and healthy working environments.
Working hours and leave
We manage working hours appropriately, including by providing work breaks and time off inaccordance with the labor laws and regulations of countries where we operate.
Wages
We pay at least the minimum wage, overtime pay and other allowances, including legally
mandated benefits, as stipulated by the labor laws and regulations of countries and regions wherewe operate, and we do not reduce wages in violation of such legal mandates.

Freedom of Association and Collective Bargaining
We respect the rights of employees, including freedom of association and the right to collective
bargaining, in accordance with international norms and the laws and regulations of countries andregions where we operate.
Remedy and Grievance Mechanism
We establish contact points for receiving complaints and reports from employees or business
partners regarding any misconduct or concerns about human rights, the environment, and otherissues, and we maintain systems that ensure whistleblowers are not subjected to disadvantageoustreatment.

3. Environment
Harmony with the environment• We continuously promote our business activity with due consideration for resource conservation,environmental protection, and biodiversity, aiming to remain consistently in harmony with theenvironment.
• We comply with the environmental laws and regulations of countries and regions where weoperate our business.
Environmental management system
We maintain environmental management systems for continuous improvements in order to reduce
our environmental impact.
Response to climate change
We strive to reduce our own company’s CO2 emissions as well as contribute to the reduction of CO2
emissions across society to support the pursuit of carbon neutrality.
Preventing environmental pollution
We give due consideration to environmental protection by complying with laws and regulations
regarding air, water, soil, and marine pollution as well as waste disposal, noise, and vibrations incountries and regions where we operate our business.
Resource recycling and Waste management
We comply with all applicable laws and regulations of the countries and regions where we operate
regarding the proper disposal and recycling of waste, and we also promote resource recycling.
Chemical substance management• We manage chemical substances in accordance with all relevant regulations and laws.
• We comply with all applicable laws, regulations, and customer requirements relating toprohibitions or restrictions regarding the use of certain substances in our products.

4. Responsible Procurement
Approach to Conflict minerals
We buy tin, tantalum, tungsten, gold, and cobalt only after confirming that these minerals were notextracted in conflict-affected or high-risk areas.

5. Business Continuity Plans
Formulation of BCPs
To ensure that we can stably supply products and services even during a crisis, such as a natural
disaster or pandemic, we maintain business continuity plans (BCes) for thorough organization-widecrisis management.

6. Relationships with Stakeholders
Information disclosure
We disclose corporate information in a timely and appropriate manner to maintain and develop
mutual understanding and trust with our diverse stakeholders through open and faircommunication.

JFE Steel may conduct questionnaires, on-site surveys, etc. to confirm the status of partners’ efforts
to comply with these JFE Steel erocurement Guidelines. If significant deviation from theseguidelines is identified, JFE Steel will follow up in an effort to encourage improvements. If noimprovement is made and significant deviations continue, JFE Steel may review its businessdealings with that partner. If any misconduct occurs with respect to these guidelines in the courseof business dealings with JFE Steel, the partner is sincerely requested to report such matters to JFE
Steel.