SUBARU
Supplier
ＣＳＲ Guidelines

Contents

I. Introduction

p.1

II. The SUBARU Group‘s CSR
1. SUBARU’s Vision- Delivering happiness to all 2. SUBARU Global Sustainability Policy
3. Six Priority Areas for CSR
4. CSR Promotion System
5. Relationship to Stakeholders
6. Fundamental Procurement Policy
7. Human Rights Policy
8. Responsibility of Conflict Minerals Procurement Policyp. 2 - 7

III. Topics and Points in the Supplier CSR Guidelines
1. Safety and Quality
2. Human Rights and Labor Issues
3. Environment
4. Compliance
5. Information Disclosure

p. 8 - 11

IV. Voluntary Inspection Checklist

p. 12

I. Introduction

Public concern about corporate social responsibility (CSR) is increasing year
after year against the backdrop of social issues triggered by such environmental
changes as global warming, globalization and advances in IT. Now that the United
Nations (UN) has adopted the Sustainable Development Goals (SDGs) and thatthese goals are to be reflected in each country’s economic policies, the resolutionof social issues and economic (corporate) development are now the integral halvesof the same whole.
In 2020, we established SUBARU Global Sustainability Policy, in replacement of
conventional CSR Policy, based on the belief that SUBARU had the responsibility
to respect all stakeholders through compliance with laws, human rights and social
norms, and a mission to contribute to the development of a sustainable society
through our business activities.
Amid our rapidly changing social environment, we reviewed our existing Eight
CSR Action Items, based on stakeholder questionnaires and other feedback, andestablished Six Priority Areas for CSR in STEP, our mid-term management vision
for the period 2018 through 2025. We aim to become a company trusted byeveryone and successfully combine the creation of a sustainable society with theenhancement of corporate value by disclosing information about each of those six
priority areas to our stakeholders, engaging in dialogue with them, and reflecting
this in the management of the business.
In the context of this, in 2012, we issued the first edition of the SUBARU Supplier
CSR Guidelines, which brought together our CSR action item in the field of
procurement, due to the need for efforts throughout the supply chain in the practiceof CSR. Following the review of our priority areas for CSR, we have recently
revised the content of “II. The SUBARU Group’s CSR.”
We are aware that these points are everyday practice in the context of our longstanding relationships of trust with our suppliers, rather than being something new.
However, we hope to share our approach to CSR at a deeper level by documenting
these points anew.
We would like to ask all our suppliers for their understanding and cooperation in
utilizing the guidelines to be of assistance in your practice of CSR while, at thesame time, expanding and promoting the guidelines among your own suppliers tofacilitate our mutual growth through CSR.
Purchasing Committee
SUBARU CORPORATION

1SUBARU Supplier CSR Guidelines

II. The SUBARU Group's CSR

1. SUBARU’s Vision- “Delivering Happiness to All” In the May 2021 mid-term management vision progress briefing for "STEP", SUBARU
consolidated the multiple corporate principles into three key pillars.

Our corporate statement is “We aim to be a compelling company with a strong market
presence built upon our customer-first principle.”
The value which SUBARU Group delivers to our customers is “Enjoyment and Peace ofMind.” We recognize that this is a value we must deliver to our customers in order todeepen the SUBARU Difference, not influenced by the changes in the times or external
environment and further enhance our brand.
Our vision is “delivering happiness to all.” We established this vision when we changed
our company name to SUBARU CORPORATION. This vision has come to us aswatching what our customers do: we learned what SUBARU should do from ourcustomers.
We will raise the medium- to long-term corporate value by continuously growing theAutomobile Division and Aerospace Division as a global brand.

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SUBARU Supplier CSR Guidelines

2. SUBARU Global Sustainability Policy:
We, SUBARU Group*, are committed to sustainable business practices designed topromote harmony between people, society and the environment in the following ways:(1) Through our business activities, we will contribute to the resolution of various
social issues, including the protection of the global environment, and to thecreation of a sustainable society.
(2) Respecting the quality and originality of our products, we will continue to provide
SUBARU’s unique value using advanced technologies and enrich the lives of all
those involved with the SUBARU Group.
(3) As a good corporate citizen in the international community, we respect human rights,
diverse values and individuality, and treat all stakeholders with sincerity in every
interaction.
(4) We strive to maintain and advance the workplace environment so that employees
can work safely in peace, and with a sense of satisfaction.
(5) We respect international rules and the laws and regulations of each country andregion, as well as local culture and customs, and pursue fair and transparent
corporate governance.
(6) We make use of dialogue with stakeholders to management decisions and disclose
corporate information in a timely and proper manner.
*SUBARU Group includes SUBARU Corporation and its all subsidiaries.

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SUBARU Supplier CSR Guidelines3．Six Priority Areas for CSR
In order for the SUBARU Group to contribute to society through its business and meetthe expectations and demands of its stakeholders, we believe it is necessary to promote
and ingrain CSR initiatives on a group-wide and global basis. To this end, we haveestablished the Six Priority Areas for CSR - "People-oriented Car Culture," "Resonanceand Coexistence," "Peace of Mind," "Diversity," "Environment," and "Compliance" - inline with our mid-term management vision "STEP”.
By adopting the concept of the Six Priority Areas for CSR while conducting business, wewill fulfill our social responsibility as a corporation and will continue to deliver“Enjoyment and Peace of Mind” to all of our stakeholders, including our customers. The
SUBARU Group will become a company trusted by society as a truly global company
and will contribute to the creation of a more affluent and sustainable society.

SUBARU Group’s
Six Priority Areas for
CSR

Vision for 2025

Contribution to SDGs

Main object categories
of "Topics and Points in
the Supplier CSR
Guidelines”(P8 - 11)

People-oriented Car
CultureBecome a company thatenriches people’s lives andminds as a partner

Resonance andCoexistence

Become a company that is
widely trusted by, resonatesand coexists with society.

1. Safety and Quality
5. Information Disclosure

Peace of Mind

Become a company thatprovides the utmost peace ofmind to all stakeholders.

1. Safety and Quality

Diversity

Promote businesses thatcreate diverse forms ofmarket values while
respecting the diverse valuesof all people.

Environment

Cherish and protect the
global environment – theearth, the sky and nature –through Group-wide
activities.

Compliance

Act in good faith and become
a company that is trusted byand resonates with society.

1. Safety and Quality

2. Human Rights andLabor Issues

3. Environment

4. Compliance

3. Good Health and Well-Being
5. Gender Equality
8. Decent Work and Economic Growth
9. Industry, Innovation, and Infrastructure
11. Sustainable Cities and Communities
12. Responsible Consumption and Production
13. Climate Action
16. Peace, Justice and Strong Institutions
17．Partnerships

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SUBARU Supplier CSR Guidelines

4. CSR Promotion System
The Sustainability Committee was established as a forum for discussing all sustainability
initiatives of the SUBARU Group and holds twice a year. The Sustainability Committee,
chaired by the President and Representative Director and attended by all executives,
examines our business from a social perspective and works to strengthen our initiatives.
CSR Promotion System

5. Relationship to Stakeholders（Information Disclosure）
The SUBARU Group’s CSR initiatives emphasize the relationship with stakeholders and
SUBARU Group believes that disclosing information to stakeholders, engaging in
dialogue with them, and reflecting their opinions and requests in our management are
all essential.
In order to realize our vision of becoming A Compelling Company with a Strong Market
Presence built upon its customer-first principle as stated in our management philosophy,
SUBARU Group will continue to make efforts to gain trust from our stakeholders, and to
make useful social contributions while at the same time increasing our corporate value.
Relationship with stakeholders

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SUBARU Supplier CSR Guidelines

6. Fundamental Procurement Policy
In keeping with our Corporate Philosophy, SUBARU Group strives to procure parts,
materials, and equipment that offer excellent quality, environmental performance, andcost performance. To realize this goal, it is necessary for us to establish relationships
with our business partners based on equality, trust, mutual benefit, and dedication tocontinuous improvement.
Fundamental Procurement Policy:
SUBARU Group has been promoting activities for sustainable procurement under thefollowing basic polices.
(1) CSR Procurement
We engage in procurement activities in a way to harmonize people, society
and the environment, and carry out our corporate social responsibility insuch ways as conducting transactions paying due care to observe legal andsocietal rules and to protect human rights and the environment.
(2) Establish Best Partnership
We establish "WIN-WIN" relationships with suppliers through transactions
based on mutual trust under the doctrine of good faith.
(3) Fair and Open Way of Selecting Suppliers
In selecting suppliers, the door is wide-open to all firms, domestic andoverseas, for fair and equitable business to procure goods and services
most excellent from seven perspectives: quality, cost, delivery, technicaldevelopment, management, environment and society (QCDDMES).
7. Human Rights Policy
The SUBARU Group, through its automotive and aerospace businesses, puts people
first and engages in people-oriented manufacturing. Respect for the rights andcharacteristics of individuals is an important management issue for SUBARU. Basedon this policy, the SUBARU Group clarifies its responsibilities to respect human rights
based on the United Nations Guiding Principles on Business and Human Rights.
This policy applies to the SUBARU Group worldwide–SUBARU CORPORATION
and its all subsidiaries, expects and encourages our business partners and otherstakeholders associated with our operations, including those in the supply chain torespect human rights in accordance with this policy.
For further details, please see: Human Rights Policy

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SUBARU Supplier CSR Guidelines

8. Responsibility of Conflict Minerals Procurement Policy

・ The SUBARU Group aims for non-use of raw materials that engender social
problems, such as infringement of human rights and environmental destruction.
・ We will clearly state this approach in the SUBARU Supplier CSR Guidelines andrequest that those in our supply chain comply with these.
・ As one of our initiatives, we will conduct an annual conflict minerals survey targetingthe direct material supply chain.
・ In this survey, we referenced the OECD Due Diligence Guidance for Responsible
Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, using theConflict Minerals Reporting Template (CMRT), a questionnaire provided by the
Responsible Minerals Initiative (RMI), and other information. We used this to trace
through the supply chain and identify smelters, working to avoid procuring raw materials
from smelters that are linked to the infringement of human rights or sources of funding
for armed groups in conflict and high-risk areas, such as countries around the
Democratic Republic of the Congo.
・ In addition, for minerals other than conflict minerals (tin, tantalum, tungsten, and gold)
such as cobalt, for which child labor is a concern in some mining, we will use theExtended Minerals Reporting Template (EMRT) questionnaire provided by RMI, as wellas other tools, to conduct due diligence. If any problems are found, we will takenecessary corrective measures.
・ In our initiatives, we will cooperate with our customers, business partners, industry
bodies, and other stakeholders, and strive to disclose information.

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SUBARU Supplier CSR Guidelines

III. Topics and Points in the Supplier CSR Guidelines
The SUBARU Supplier CSR Guidelines are based on the CSR Guidelines for Suppliers
issued by the Japan Automobile Manufacturers Association, Inc. (JAMA) and incorporate
SUBARU Global Sustainability Policy.
As stated in Fundamental Procurement Policy (page 6), the SUBARU Group selects
suppliers of goods and services not only based on QCDD, but also from a multifaceted
perspective that includes corporate governance (M, compliance, etc.), the environment (E),and society (S, human rights, etc.).
We expect complying these guidelines will help our partners to expand and promote CSR
activities jointly with their own business partners.
1. Safety and Quality○Providing products and services that meet consumer and customer needs
We identify consumer and customer needs to develop and provide productswith social utility.** Products with social utility: for example, products that are easy for anyone touse irrespective of age, gender, and disability. Alternatively, earth-friendly
products, such as those that contribute to energy and resource conservationand environmental protection○Providing appropriate information concerning products and services
We provide consumers and customers with appropriate information concerning
products and services.
○Ensuring safety of products and services
We produce and provide products and services that meet the safety laws andregulations stipulated in each country and region.
○Ensuring quality of products and services
We create and operate companywide structures to ensure quality.
2. Human Rights and Labor Issues○Striving to avoid discrimination
We do not discriminate on the grounds of race, ethnicity, country of origin, religion,
gender or any other pretext in any employment situation.**Any employment situation = recruitment, hiring, promotion, wages, dismissal,
retirement, allocation of duties, discipline, etc.

○Respecting human rights
We do not tolerate any form of harassment on the grounds of race, ethnicity or
country of origin, religion, gender or any other pretext in our workplaces.
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SUBARU Supplier CSR Guidelines

○Prohibiting child labor
We do not permit the employment of children who have not reached the legal ageof employment in each country and region.
○Prohibiting forced labor
We do not engage in forced labor, making certain to ensure that all labor isvoluntary and that employees are free to leave their jobs.
○Not using raw materials that cause social problems
We aim not to use raw materials related to human rights infringements, such asconflict minerals,* and strive to identify conditions and respond appropriately.
*Conflict minerals: Minerals that have concern to be involved in support to Nongovernment armed group, Human rights violation and illegal action.
According to Dodd-Frank Wall Street Reform and Consumer Protection Act, theminerals produced in the Democratic Republic of the Congo and surrounding
countries such as Tin, Tantalum, Tungsten and Gold, to fund the activities ofarmed groups in the region○Compliance with the law on remuneration
We comply with the laws in each country and region related to minimum wages,
overtime work, payroll deductions, piecework wages, and other benefits.
○Compliance with the law on working hours
We comply with the laws in each country and region related to the determination of
the working hours of employees (including overtime work) as well as the provisionof holidays and annual paid leave.
○Practicing dialogue and consultation with employees
We engage in consultation and dialogue in good faith with the representatives of
employees or employees.
We recognize employees’ rights of free association in accordance with the laws ineach country and region.
○Ensuring a safe and healthy working environment
We strive to prevent accidents and disasters with ensuring the safety and health of
employees at work as our priority.
○Providing human resource training
We train human resources that can take action to detect and resolve problems
independently.

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SUBARU Supplier CSR Guidelines

3. Environment○Implementing environmental management
In order to promote wide-ranging environmental activities, we comply with thelaws of each country and region while building companywide management
structures which we continuously operate and improve.
○Reducing greenhouse gas emissions
In order to contribute to reducing greenhouse gas emissions, we manage
greenhouse gas emissions in our business activities and promote activities toreduce them. In addition, we strive to utilize energy effectively.
○Preventing air, water, and soil pollution
We comply with the laws of each country and region regarding air, water, and soil
pollution in addition to continuously monitoring and reducing contaminants toprevent environmental pollution.
○Saving resources and reducing waste
We comply with the laws of each country and region regarding the appropriate
disposal and recycling of waste in addition to working to reduce the final disposal
volume of waste by utilizing resources effectively.
○Managing chemical substances
We manage chemical substances with the potential to pollute the environment
safely.
Our products do not contain chemical substances prohibited by the laws of eachcountry and region in the relevant country and region. We do not use prohibitedchemical substances in the manufacturing process, and, with regard to chemical
substances provided for under the laws of each country and region, we identify
emissions and report them to the government in accordance with the law.
○Conservation of biodiversity
In general business activities including procurement of parts and materials, we
strive to pay due cate to conservation of biodiversity.
* With regard to the environmental points above, SUBARU’s specific requests to
suppliers are compiled separately in the SUBARU Green Procurement
Guidelines, so please also refer to these.

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SUBARU Supplier CSR Guidelines

4. Compliance○Compliance with laws
We comply with the laws in each country and region.
We establish and operate structures that include policies, systems, conduct
guidelines, whistleblowing systems, and education in order to fully enforce
compliance.
○Compliance with competition laws
In compliance with competition laws in each country and region, we do not engage
in such practices as private monopolies, unreasonable trade restrictions (cartels,
bid rigging, etc.), unfair trade practices, and abuse of a superior bargaining
position.
○Preventing corruption
We make political donations and contributions in accordance with the laws in eachcountry and region and strive to build transparent and fair political andadministrative relationships.
We do not exchange entertainment, gifts or money with our business partners forthe purpose of securing and maintaining unfair privileges and preferential
treatment.
○Managing and protecting confidential information
We obtain the personal information of customers, third parties and our employees
and the confidential information of customers and third parties by lawful means.
We also strictly manage and protect such information and utilize it within theproper scope.
○Managing export trading
We implement the proper export procedures and management related to theexport of technologies and goods provided for under the laws of each country andregion.
○Protecting intellectual property
We protect intellectual property rights that belong to or are attributable to SUBARU,
and we do not unlawfully obtain and use or infringe the intellectual property rightsof third parties.
5. Information Disclosure○Disclosing information to stakeholders
We disclose information that includes our financial position and performance andthe content of business activities to stakeholders in a timely and appropriatemanner. We also strive to maintain and develop mutual understanding and trusting
relationships with stakeholders through open and fair communication.
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SUBARU Supplier CSR Guidelines

IV. Voluntary Inspection Checklist

SUBARU has prepared a voluntary inspection checklist for CSR activities to facilitate
self-diagnosis and self-improvement by suppliers.
We would appreciate the use of the basic pattern below when setting questions andanswers for each CSR field and item.
Checklist
QuestionLegal
regulations

Have you identified thelaws, regulations andrules you have to comply
with?

SystemHave you determined thedepartment and staff withresponsibility?

Prevention

Do you have policies,
systems, rules, andprocedures to ensureinternal compliance?

Education

Do you carry out
educational activities for
employees?

Actualcircumstance

Have you identified theactual circumstances
through internal surveys?

Answer (multiple choice)(1) We are constantly identifying the most upto-date information.
(2) We have identified most of the important
information.
(3) We identify information on an ad hoc basis.
(1) We have clearly determined them based on
rules, etc.
(2) We have determined them although there
are no rules, etc.
(3) We determine them on an ad hoc basis.
(1) Written policies, systems, rules, andprocedures are provided.
(2) There are unwritten but de facto policies,
systems, rules and procedures.
(3) We determine the policies, systems, rules,
and procedures on an ad hoc basis.
(1) We carry out educational activities regularly.
(2) We carry out educational activities
irregularly or for some employees.
(3) We carry out educational activities on an ad
hoc basis.
(1) We regularly carry out internal surveys andalways understand the actual circumstances.
(2) We carry out internal surveys, thoughirregularly, but do endeavor to understand theactual circumstances.
(3) We carry out internal surveys on an ad hoc
basis.

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SUBARU Supplier CSR Guidelines

First issued March 2012
Revised August 2022
SUBARU CORPORATION
Purchasing Committee
SUBARU of INDIANA AUTOMOTIVE INC. (SIA)