

The contents of this pamphlet are also available
for viewing on the Internet.

Sumitomo Rubber Industries, Ltd.
Corporate Ethics Committee Secretariat

Message from the President and CEO
President and CEO, Representative Director

Sumitomo Rubber Industries, Ltd.

Table of Contents
Message from the President and CEO …………………………………… 1
The Relationship Between“Our Philosophy” & Our “Code of Conduct” …………………………… 2
About Our Code of Conduct ……………………………………………… 4
Contacts for Compliance Consulting & Reporting…………………… 6

Compliance Self-Checks…………………………………………………… 8Case Studies ………………………………………………………………… 8

Ⅰ．Relationship Between Company & Employees
Ⅰ- １ Valuing Human Life & Maintaining Safety & Health……… 10Ⅰ- ２ Respect for Personality & Individuality ……………………… 11
Ⅰ- ３ Fair Evaluations & Compensation, Skill Development……… 12
Ⅰ- ４ Protecting Corporate Assets ………………………………… 13
Ⅰ- ５ Prohibition Against Conflicts of Interest …………………… 14

Ⅱ．Engaging in Business Activities
Ⅱ- １ Providing Goods & Services …………………………………… 15
Ⅱ- ２ Information Management & Protection
Ⅱ- ３ Fair Competition…………………… 16……………………………………………… 17

Ⅱ- ４ Dealings with Contractors & Suppliers ……………………… 18
Ⅱ- ５ Protection of Intellectual Property …………………………… 19
Ⅱ- ６ Export Controls ………………………………………………… 20
Ⅱ- ７ Restrictions on Entertaining, Gifts, Donations, Etc.

……… 21Ⅱ- ８ Relations with Public Officials ………………………………… 22
Ⅱ- ９ Timely Disclosure of Information…………………………… 23

Ⅱ-10 Prohibition Against Insider Trading ………………………… 24

Ⅲ．Relationship Between Company & Society
Ⅲ- １ Abiding by Laws & Social Norms…………………………… 25

Ⅲ- ２ Dealing with Antisocial Forces……………………………… 26

Ⅲ- ３ Involvement in Politics ………………………………………… 27
Ⅲ- ４ Sustainability Efforts …………………………………………… 28
Ⅲ- ５ Abiding by Local Rules in Each Country…………………… 29

Dear fellow members of the Sumitomo Rubber Group,“Our Philosophy” and the “Sumitomo Business Philosophy” represent the fundamental ideals
that all of us ought to cherish and uphold above all else. Simply put: business strategies andmid-to-long-term business plans that ignore these core values can only turn out hollow anddestined for failure. As we all know by now, companies throughout the world are increasingly
being judged not just in terms of their economic value, but also in terms of their value tosociety. Terms such as “ESG,” “SDGs” and “Compliance” have now come into common
parlance, which is a clear sign that companies that are unable to live up to these ideals will
not be able to survive for much longer.
▪When it comes to how we go about our work and how decisions are made, can we all say
with confidence that our own workplaces are completely free of actions and decisions thatgo against the ideals of Our Philosophy and the Sumitomo Business Philosophy?
▪When faced with a situation that treads the line on compliance, will we be able to make adecision that prioritizes compliance above sales, profits and productivity?
▪Can everyone in our workplaces practice “Bad News First/Fast” without hesitation?
Whenever you are having trouble, struggling or just need some help with something, pleasefeel free to seek out the support of your colleagues. The Sumitomo Rubber Group is full ofkindhearted, capable people who can and will help you out with whatever is bothering you.
When there is a problem that you cannot solve on your own, then perhaps you canovercome it with help and support from your colleagues. It goes without saying that it is verymuch to the benefit of our Group when problems are solved in this way.
Whenever you are unsure about a decision in the course of your day-to-day work, please be
sure to return to the very starting point for all of our actions and decisions: this Code of
Conduct. At the same time, I also hope that all of you will occasionally take the time to think
to yourselves about whether or not you can tell your friends and families about your own
actions with pride in your hearts because you have nothing to hide.
In addition, if you happen to notice some untoward action in your workplace and believe that
there is even a slight chance that this action is contrary to our Code of Conduct, please do
not hesitate to report it to your superiors or through our internal reporting office.
As members of the Sumitomo Rubber Group, each and every one of us bears a responsibility
to understand and uphold our Code of Conduct.
As such, reporting potential infractions whenever they arise is not only the right thing to do,but is also a solemn duty for each of us.
While looking kindly on your courage in speaking up, the Sumitomo Rubber Group willhandle the matter with the full gravity that it deserves. As long as you report your concerns
in good faith, I promise you that you will never be subjected to any form of reprisal or otherdisadvantageous treatment as a result.
I am truly grateful to everyone for all of the hard work that you do for the Sumitomo RubberGroup each and every day. Moreover, I am especially grateful that you are all working in a
way that is consistent with Our Philosophy.
Let us all continue to work for the further growth and development of the Sumitomo RubberGroup while ensuring that we always act in a manner that is honest and aboveboard.
July 1, 2022

The Relationship Between “Our Philosophy”& Our “Code of Conduct”
Our Philosophy: The Corporate Philosophy Framework of theSumitomo Rubber GroupIn order to ensure the continued growth of our Group during these times of great
uncertainty and drastic changes, it is essential that we now return to square one andmake perfectly clear the very reason why the Sumitomo Rubber Group exists so that we
may then use this reason as our basis for establishing a set of unwavering guiding
principles to share with all of our stakeholders and especially among all of our employees.
With this lofty goal in mind, we formulated Our Philosophy as a new and improved
Corporate Philosophy Framework for the entire Sumitomo Rubber Group, one that builds
upon the foundations set by the Sumitomo Business Philosophy, which has been passed
down through generations and still lives on to this day.
With Our Philosophy serving as the basis for our every decision and as the impetus for our
every action, the Sumitomo Rubber Group will continue striving to improve not only our
economic value, but also our value to society so that we may contribute to the realizationof a prosperous and sustainable society.

Through innovation we will create
a future of joy and well-being for all.


Uniting our diverse strengths, growing together,driving and thriving on change.

SRI WAY - Values
Being reliable and worthy of trust

Facing forward with honesty and integrity, responding to the trust our customers,
our colleagues and our society place in us.

Article 1. Sumitomo shall achieve strength and prosperity by placing prime importanceon integrity and sound management in the conduct of its business.

Article 2. Sumitomo shall manage its activities with foresight and flexibility in order tocope effectively with the changing times. Under no circumstances, however,shall it pursue easy gains or act imprudently.

※Modern Translation from “Sumitomo Limited Partnership Administrative Regulations” (Enacted in 1928)

Code of Conduct
Our Code of Conduct is a set of substantive guidelines that explain in easy-to-understandterms the basic mindsets and ideas that underpin the business activities of the Sumitomo
Rubber Group, beginning with matters of compliance. We ask that all executives andemployees of all companies in the Sumitomo Rubber Group rely on this Code of Conduct
as essential criteria for all of the decisions involved in carrying out the business activitiesof the Sumitomo Rubber Group.
※Our Philosophy is indicated in the gray area

Sumitomo Rubber's reason for being.
What does Sumitomo Rubber exist to do?

The state we aspire to in order tobring our Purpose to life.



Seeking out challenge

Being unafraid; having the courage to persist in the face of failure.

Valuing one another

The underpinnings of our Purpose.
The beliefs that shape Sumitomo Rubber.



The values each member of
Sumitomo Rubber holds in order torealize our Vision and embody
our Purpose.

Understanding and respecting each otherʼs individuality and perspective.

 

Rubber and Beyond, Driving Our Future2

Sumitomo Business Philosophy

The Sumitomo Business Philosophy
in the heritage of wisdom accumulated
since its foundation 400 years ago.

Code of Conduct

The basis for Our Philosophy is the Sumitomo Business Philosophy, a set of ideals thathave been passed down through generations since the founding of the Sumitomo Groupsome 400 years ago.
The Sumitomo Business Philosophy began as “Monjuin Shiigaki” ( “The Founder’ s
Precepts” ), a collection of straightforward business guidelines for merchants that
Masatomo Sumitomo (1585–1652) left behind for posterity after founding the businessthat would become the Sumitomo Group. Over the years, as the Sumitomo Group grew
into one of largest conglomerates in Japan, these guidelines continued to develop andexpand until they were finally condensed into the more modern “Business Principles,”which remain in use throughout the Sumitomo Group to this very day.

Guidelines Deﬁning Basic Mindsets & Proper Actions to
Ensure Compliance with All Applicable Laws, Regulations &Norms of Corporate Ethics

A unique belief in the material possibilities of rubber.
A track record of multiple world ﬁrsts through industry-leading rubber technology,
and beyond that, relentless dedication to the innovation and development of new technologies.
A singular focus on creating value that exceeds expectations in response to the trust ourcustomers and society place in us.
Supporting individuals, society, and the future ;through innovation creating a future of joy and well-being for all.
We are Sumitomo Rubber Industries, and this is what we are for.

The Sumitomo Business Philosophy※Basis of Our Philosophy

3About Our Code of Conduct
Who is subject to our Code of Conduct?

This Code of Conduct applies to all executives and employees of all companies in the
Sumitomo Rubber Group.
In addition, we also expect all suppliers who do business with the Sumitomo RubberGroup to act in a manner that is consistent with our Code of Conduct.

Relationship with Local Laws in Each Country

All executives and employees must fully abide by all applicable laws, regulations and rulesin every country and region where we operate. Where local laws or regulations differ fromthe contents of this Code of Conduct, please contact and consult with our Legal Affairs
Department.
Some companies in the Sumitomo Rubber Group have established corporate rules whose
contents overlap with this Code of Conduct, either in part or in full. Where such corporate
rules conflict with this Code of Conduct, the contents of this Code of Conduct shall takeprecedence.

Compliance Consulting & Reporting

This Code of Conduct does not comprehensively address every situation that may
possibly arise. As such, please contact any one of the contacts for consulting andreporting listed on Pages 6 and 7 in all of the following cases.
▪When you are unsure about the specific requirements of laws, regulations or corporate
policies, etc.
▪When you are unsure whether your own actions (or the actions of those around you)are correct.
▪When you suspect that your own actions (or the actions of those around you) arewrong.
Should you suspect or become aware of any violation of applicable laws or regulations,this Code of Conduct or other corporate rules, etc., then you have an obligation to reportthis. Duly reporting suspected or actual misconduct or other problems serves to protect
your company, your coworkers and your community.

Our Responsibilities
▪We have a responsibility to understand and uphold this Code of Conduct, as well as all
corporate policies and other corporate rules.
▪Whenever we have any questions or concerns relating to compliance and especiallywhenever we become aware of any potential violation of applicable laws or regulations,this Code of Conduct or other corporate rules, we have an obligation to contact any
one of the contacts for consulting and reporting listed on Pages 6 and 7.
▪We need to understand that we may be subject to punishment if we act in a way that
contravenes this Code of Conduct.

Responsibilities of Superiors            
         

▪Please always act in a manner that sets a positive example for those around you.

▪Please regularly check with members of your workplace to ensure that they not only
understand the importance of this Code of Conduct, but also act accordingly at all
times.
▪Please work to create a work environment where everyone feels free to raise anddiscuss questions or concerns relating to compliance without hesitation.
▪Please listen to members of your workplace when they come to you with questions orconcerns relating to compliance while always making sure to take their concerns
seriously.
▪You have a duty to handle and resolve any compliance concerns that fall within thescope of your authority.

Bad News First/Fast“Bad News” (i.e. trouble, etc.) demands prompt reporting up thechain of command so that it can be addressed quickly. By contrast,“Good News” can wait.
Whenever Bad News arises (or appears imminent), please
relay the facts as quickly as possible and without hiding or
distorting anything.
In certain cases, failure to practice “Bad News First/Fast”
may be subject to punishment.
On the other hand, our rules dictate that practicing “BadNews First/Fast” will never reflect poorly on you, even if
the news that you reported is not as bad as you had
thought or does not turn out as you had expected.
At the same time, bosses and executives bear an
obligation to strive to create a work environment thatfacilitates the unimpeded flow of Bad News.

▪Upon learning of possible misconduct, you have an obligation to contact any one of thecontacts for consulting and reporting listed on Pages 6 and 7.
▪Please take the initiative in promoting and advancing groupwide compliance efforts
while also actively participating in local compliance efforts at your own place of work.

4

5

Contacts for Compliance Consulting & Reporting
Superiors

Please first consult with your direct superior for reporting through the chain of command.
If you are unable or unwilling to consult with your direct superior for whatever reason,
please feel free to consult with one of the other contacts listed on the following.

Legal Affairs Organization

If you have questions about legal compliance or simply wish to know more about legalrisks, please contact the organization in your company that is responsible for legal affairs.

Human Resources & General Affairs Organization

If you wish to know more about general compliance concerns or have questions about
corporate ethics, please contact the organization in your company that is responsible forhuman resources and general affairs, as they can support you in finding the best way toaddress such concerns.

Local Compliance Office & Head Office Corporate Ethics Helpline

The Sumitomo Rubber Group has established a Corporate Ethics Helpline to serve as acentral office for collecting information and responding to inquiries concerning potential
and actual violations of laws and regulations or norms of corporate ethics.
All Sumitomo Rubber Group employees anywhere in the world, as well as our business
partners (i.e. customers, suppliers, etc.) worldwide, may freely contact the Corporate
Ethics Helpline for consulting or reporting.
If consulting or reporting from outside of Japan, please contact the Corporate Ethics
Helpline by email. (※Gmail and other free email services may also be used to contact the
Corporate Ethics Helpline for consulting and reporting.)
Sumitomo Rubber Group employees may choose to contact either their local Compliance
Office (where available) or the Corporate Ethics Helpline at the Head Office.
The Sumitomo Rubber Group encourages all employees to make active use of local
Compliance Offices or the Corporate Ethics Helpline whenever the need arises.
Please rest assured that your privacy will be thoroughly protected and that you will notreceive any form of reprisal or other disadvantageous treatment as a result of having
consulted or reported.

Sumitomo Rubber Group Corporate Ethics Helpline①Compliance Consultation
OfficeTelephone:(+81) 78-265-3133(+81) 50-3495-8488
Email Address:
helpline@srigroup.co.jp
Mailing Address:

Corporate Ethics Committee

Notification as necessary

Corporate Ethics Help Line
Compliance Consultation OfficeDirectConsultation

Cooperate as necessary

External Liaison Office:Dojima Law Office●Feedback on consultation items●No disadvantageous treatment resulted from consultation●Confidentiality of person seeking consultation maintained

DirectConsultation

Sumitomo Rubber Group executives, employees and our business partners

6

Email Address:

sri.helpline@dojima.gr.jp

You can also accessinformation about
the Corporate Ethics
Helpline online.

Mailing Address:

Dojima Law Office
2-3-9 Kitahama, Chuo-ku,
Osaka JAPAN(Postal Code: 541-0041)

So that you may feel comfortable when consulting or reporting, the above oﬃces have both men
women on staﬀ who can speak with you if you have a preference.
Please understand that making false reports, etc. with the intention of sabotaging or slandering aparticular individual or otherwise abusing the Corporate Ethics Helpline for the furtherance of
misconduct is strictly prohibited.

Handling of Consulting & Reporting by the Corporate Ethics Helpline

When you contact the Corporate Ethics Hotline, things will generally play out as follows.
However, please note that the actual sequence of events may vary depending on thespecifics of the case at hand.
Receipt ofConsultation/Report①We will ensure strict confidentiality while minimizing the number ofpeople involved in an investigation.
Your information will be maintained in strict confidence.
You may consult or report anonymously if you so choose.
You will not receive any form of reprisal or other disadvantageous
treatment as a result of your consultation or report.
②We will interview the individual who made the initial report andinvestigate the material facts of the case.
③We will interview other persons involved in the case.

Investigation

Audit & Supervisory Board

Notification as regularly

Telephone:(+81) 6-6201-0361

Compliance Consultation Office
Sumitomo Rubber Industries, Ltd.
3-6-9 Wakinohama-cho,
Chuo-ku, Kobe JAPAN(Postal Code: 651-0072)

Structure of Compliance initiatives
Board of Directors②External Liaison Office:Dojima Law Office※Where a consultation or report involves accusations or suspicions ofcompliance infractions committed by a specific individual or individuals,
we will also interview the individual(s) in question.
※It is very important that you also maintain confidentiality after consulting
or reporting. Sharing information about a case with others increases thelikelihood that you will be identified as the person who made the initialreport and may cause undue confusion during an ongoing investigation.

Implementing
Corrective Action &Measures toPrevent Repeat Incidents④We will determine the facts with regard to the initial consultation orreport and, based on our findings, will take corrective action andimplement measures to prevent repeat incidents.

Feedback⑤We will provide feedback on how the matter was ultimately
addressed and resolved to the individual who originally contacted
us with a consultation or report.
※This may not be possible in the case of anonymous consulting or reporting.

Follow Up⑥We will check to make sure that no person has been subjected toany form of reprisal or other disadvantageous treatment as a resultof having consulted, reported, facilitated reporting or cooperated
with an investigation into the facts of a case.
We will enact appropriate measures for the relief and rehabilitation of any
person who has been subjected to reprisal or other disadvantageous
treatment for any of the reasons listed above.

7

Compliance Self-Checks
Whenever you find yourself facing a compliance issue with no clear answers in sight,
please be sure to ask yourself the following questions.

OfficeDo you believe that this action is correct?
Can you tell your family about this with pride because you
have nothing to hide?
Do you think that this is okay only as long as nobody finds
out about it?
If this made the news, would you still be able to explain youractions with confidence?
Will this action build trust and inspire pride in the Sumitomo
Rubber Group?

Case Studies
The following is a list of typical situations that you may encounter in the course of yourday-to-day work.
Please check to make sure that none of the following descriptions apply to any of youractions.

Negotiations,Meetings & Entertaining
with Business Partners▪Are you engaging in discrimination, harassment or other violations of human rights? To P.11
▪Are you unilaterally imposing any unfair trade terms on suppliers or contractors ordelaying payment when it is due? To P.18
▪Are you engaging in any unfair trade practices, such as by taking advantage ofmonopolies or cartels? To P.17
▪Are you providing any form of illicit benefit, entertainment or gifts, etc. to public
servants (either local or foreign)? To P.22
▪Are you providing any excessive (i.e. beyond generally accepted business practices)
entertainment or gifts, etc. to business partners or receiving any excessive
entertainment or gifts, etc. from business partners? To P.21
▪Are you sharing insider information (either about our Group or our business partners)
with any outside party without explicit authorization to do so? To P.24
▪Are you involved with antisocial forces in any way, shape or form? Are you involved withmoney laundering in any way, shape or form? To P.26
8

▪Are you engaging in discrimination, harassment or other violations of human rights? To P.11
▪Is the safety and health of workers being given top priority? To P.10
▪Are you working (or having your subordinates work) excessively long hours? To P.10
▪Are you making any judgments or decisions that deviate from corporate rules? To P.4▪Are you using any IT devices, software or communication network systems, etc. in amanner that is unauthorized or unlawful? To P.13
▪Are you engaging in any untoward accounting or bookkeeping practices? To P.23
▪Are all corporate secrets (such as information about business partners and personal
information) being handled and managed in an appropriate manner? To P.16
▪Are you sharing insider information (either about our Group or our business partners)
with any outside party without explicit authorization to do so? To P.24

Factories & Other Production Sites▪Are you engaging in discrimination, harassment or other violations of human rights? To P.11
▪Is the safety and health of workers being given top priority? To P.10
▪Are you working (or having your subordinates work) excessively long hours? To P.10
▪In the interests of ensuring product safety, are all relevant laws and regulations, quality
standards and specifications agreed with business partners, etc. being followed to theletter? To P.15
▪Are all applicable environmental laws and regulations being followed? To P.28
▪Is any secret information relating to manufacturing or technology being leaked tooutside parties? To P.16

International Relations & Trade▪Are you engaging in discrimination, harassment or other violations of human rights? To P.11
▪Are you engaging in any untoward accounting, bookkeeping or tax practices? To P.23
▪Are you engaging in any import or export procedures that deviate from the rules set
forth in international treaties or applicable laws and regulations? To P.20
▪Are you providing any form of illicit benefit to public servants involved in customs
clearance? To P.22
▪Are you engaging in any imports or exports that are banned by applicable laws or
regulations or otherwise taking part in any untoward transactions? To P.20
9

Ⅰ Relationship Between Company & Employees

Ⅰ－ 1 Valuing Human Life & Maintaining Safety & Health
The Sumitomo Rubber Group considers each and every one of our employees to be aninvaluable asset supporting the continued growth and development of our business. As
such, we value the lives of our employees and strive to create workplaces where everyone
can work in safety, good health and peace of mind.
▪Considering “Safety” and “Health” to take precedence over all other considerations, theSumitomo Rubber Group actively implements safety systems and installs facilities andequipment designed to prevent occupational accidents so that we may ensure the safety
and health of all of our employees.
▪Believing that maintaining the mental and physical health of our employees is key to thecontinued growth and development of our business, the Sumitomo Rubber Group promotes“Health & Productivity Management” and strives to create a “Health-Conscious Culture” inwhich all employees are considerate about one another’s health and actively take part in
activities to promote better all-around health.
▪With robust programs to support employees returning to work after taking mental healthleave and employees receiving ongoing medical treatment, the Sumitomo Rubber Group
strives to create workplaces where illness is not an obstacle to continuing work.
▪The Sumitomo Rubber Group is working to create a culture of mutual aid while actively
encouraging employees to take full advantage of childcare leave and other programs
meant to support those who have special needs outside of work. At the same time, we
also strive to empower employees to achieve the level of work-life balance that works bestfor them through various programs to accommodate diverse lifestyle and career choices,
including special leave for employees who choose to accompany their spouses on overseas
assignments and so forth.
▪The possession and use of illegal narcotics is strictly prohibited, as is the consumption of
alcohol in the workplace. The abuse of narcotics and alcohol not only endangers the abuser
himself or herself, but also exposes those around him or her to danger as well. In order toprovide a work environment where everyone can work in safety and peace of mind, theSumitomo Rubber Group may test employees for narcotic or alcohol use where permitted
by local laws and regulations.
As employees of the Sumitomo Rubber Group, we are expected to practice the following.

－We are required to fully abide by all rules related to safety and health while actively
participating in various safety and health activities. In addition, we are also expected tocomplete all mandatory education and training concerning safety and health.
－With an understanding that our own safety and health are ultimately our own responsibility,
we are expected to work together with coworkers in ongoing efforts to maintain safety andhealth in our workplaces.
10

Ⅰ－ 2 Respect for Personality & Individuality
The Sumitomo Rubber Group respects the personality, individuality and privacy of
everyone who works with us. Therefore, the Sumitomo Rubber Group strives to maintainwholesome workplaces where no person is ever harassed or discriminated against forreasons relating to any ideology, faith, religion, race, ethnicity, skin color, nationality,
language, social class, gender, sexual orientation, gender identify, age, mental or physicalhandicap, employment situation or circumstances of hiring, etc.
▪The Sumitomo Rubber Group views power harassment, sexual harassment and other formsof harassment as a serious human rights issue that harms the dignity of individuals while
contributing to a more hostile work environment for everyone. Thus, we aim to create
wholesome workplaces where everyone can enjoy worthwhile work in safety and peaceof mind. Toward this end, we are engaged in extensive efforts to foster mutual respectamong our employees so that nobody in our Group will “engage in, allow, tolerate or ignoreharassment in any way, shape or form.”▪The Sumitomo Rubber Group takes a strict stance against power harassment, which involves
abusing one’s status or position to denigrate the character or harm the dignity of anotherperson or persons. We do not engage in, allow or tolerate power harassment.
▪The Sumitomo Rubber Group takes a strict stance against sexual harassment: we do not
engage in, allow or tolerate sexual harassment. We strive to ensure that no employee isvictimized by unwanted comments or actions of a sexual nature in the workplace. We also
understand sexual harassment to include overbearing intrusions into a person’s private life,
which includes prying into matters of marriage and pregnancy, etc.
▪T he Sumitomo Rubber Group does not tolerate behaviors that create a hostile work
environment, including comments or actions that hinder an employee’s right to make use ofcompany programs related to pregnancy, childbirth, childcare or family care, etc.
As employees of the Sumitomo Rubber Group, we are expected to practice the following.

－We are expected to behave in an appropriate manner at all times, based on anunderstanding that power harassment and sexual harassment can occur outside of theworkplace and outside of working hours, such as in the course of interacting with business
partners or jobseekers, etc.
－We are expected to work to understand one another and respect each other’s individuality
and viewpoints.We are expected to contribute to the creation of agile organizations throughactive teamwork that thrives on diversity as well as motivation that is shared by all.
－We are expected to be respectful of varying viewpoints and diverse attributes while actingwith an awareness of our own unconscious biases so that we can create workplaces where
every individual is able to harness his or her own unique abilities to their fullest.

11

Ⅰ Relationship Between Company & Employees

Ⅰ－ 3 Fair Evaluations & Compensation, Skill Development

Ⅰ－ 4 Protecting Corporate Assets

The Sumitomo Rubber Group strives to implement and operate personnel systems that
evaluate and compensate each and every employee in a way that is fair and equitable toall.

The Sumitomo Rubber Group shall diligently manage tangible and intangible corporate
assets, utilizing these assets effectively to maximize the profits of our Group while
protecting them from loss, damage, theft or misuse.

▪T hrough our personnel systems, the Sumitomo Rubber Group actively promotes skill
development for all of our employees so that each and every employee may enhance his or
her own job performance while expanding and improving his or her own work.

As employees of the Sumitomo Rubber Group, we are expected to practice the following.

▪Through our personnel systems, the Sumitomo Rubber Group strives to create a work
environment where each and every employee remains motivated to work, driven by a sensethat his or her work is meaningful and worthwhile.
▪With the aim of promoting employee skill development, the Sumitomo Rubber Group offers
various types of training and lectures while also providing support for those who wish toparticipate in external training, seminars or other learning activities on their own initiative.
As employees of the Sumitomo Rubber Group, we are expected to practice the following.

－We are expected to encourage and push each other in the direction of mutual growth inorder to maximize the combined strength of our team as a whole.
－We are expected to take the initiative in tackling difficult challenges and accomplishing featsthat have never been done before without fear of failure.

－The use of corporate funds, devices, vehicles, equipment, supplies, software and othercorporate assets is permitted only to the extent that is necessary for us to carry out ourwork. Therefore, we may not use corporate assets for private purposes unrelated to thecompany’s business activities or for other purposes not explicitly approved by the company,
including the use of company phones for private calls or the use of company computers forprivate emails.
－In order to prevent loss, damage, theft or misuse of corporate assets, we are expected touse corporate assets in a prudent manner and to handle corporate assets with due care
under a robust management system that includes ledger management, proper storage (suchas in safes, etc.) and management of keys, etc.
－When we retire, we must return all corporate assets and all work-related data, documents
and so forth to the company. After retirement, we may not use corporate assets or data
without the express permission of the company. Further, our duty of confidentiality remains
in effect in perpetuity, even after our retirement.
－Upon noticing the loss or theft of any information devices on loan from the company, please
promptly contact the organization within your company that is responsible for information
systems.
Emergency Contact:(Within Japan): (+81)78-265-3081 (Available 24/7 Year-Round)(Overseas Group Companies): P lease contact the organization in your company that is
responsible for information systems.

1213

Ⅰ Relationship Between Company & Employees

Ⅰ－ 5 Prohibition Against Conflicts of Interest
The Sumitomo Rubber Group strictly prohibits any actions that create (or may possibly
create) any conflict of interest between our Group and any individual employee or
executive.
As employees of the Sumitomo Rubber Group, we are expected to practice the following.

－If a conflict of interest (or the possibility thereof) should arise, we must immediately report
this to our superiors or to the responsible department.
－We must not become employees or executive officers of business partners (suppliers,
customers, etc.) or competitors of the Group or invest in such a company.
－We must not abuse our capacity as Group employees to engage in business dealings withcompanies that are owned by ourselves or our friends or family members or any othertransactions that raise questions concerning fairness and impartiality.
－We must not accept excessive entertainment or gifts from business partners (suppliers,
customers, etc.) even if we have no intention of providing any particular benefit or utility to
said business partners in return.
－We must not use any information that we have learned in the course of our work for our own
benefit or for the benefit of some other party outside of our Group.
－We must not make fraudulent applications for the reimbursement of travel costs or otherexpenses.
－We must not conspire with business partners (suppliers, customers, etc.) to engage infictitious or round-trip transactions or to inflate invoices.

Ⅱ Engaging in Business Activities

Ⅱ－ 1 Providing Goods & Services
The Sumitomo Rubber Group considers it our top priority to provide products andservices that are safe and appealing, that fulfill customer quality requirements and thatcomply with all applicable laws and regulations.
▪Our business activities are premised on our ability to live up to the trust that our customers
place in us, which means providing quality products and services while making sure that nodamage to human life, health or property will come about as a result of any defect in our
products.
▪I n order to ensure that we provide safe products and services that fulfill customer
requirements while complying with all applicable laws and regulations, the Sumitomo
Rubber Group carries out all product processes in accordance with the framework
established by our Quality Management System (QMS), which encompasses everythingfrom research and development to manufacturing, processing, inspections, distribution andsales.
As employees of the Sumitomo Rubber Group, we are expected to practice the following.

－Quality assurance is the very cornerstone of our business activities. At the same time,
however, quality assurance is not something that is carried out by any specific employees ordepartments, but by all employees and all departments. It is an ongoing groupwide activity
that encompasses sales, research and development, manufacturing, support departments
and so on. We are expected to understand this and to act accordingly.
－In carrying out our work, we must not deviate from manuals, disregard quality control
standards, falsify inspection results or otherwise act in a way that sacrifices quality for thesake of cost or expedience.
－Where we have concerns about the safety of a product due to a customer claim, accident orother product trouble, we must promptly report these concerns to our superiors and to the
Quality Assurance Department.
－In the event of an accident involving one of our products, we must respond in a mannerthat gives top priority to customer safety. This includes providing customers with true andaccurate information while taking appropriate corrective action in good faith.

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Ⅱ－ 2 Information Management & Protection
The Sumitomo Rubber Group considers information (including personal information)
about customers and business partners obtained in the course of business dealings,
technical and business information (i.e. trade secrets) in the possession of groupcompanies as well as personal information about our employees to be an invaluable
and essential asset to our Group. Recognizing that unauthorized disclosure or leaks ofsuch information would have a negative impact on our business activities, the Sumitomo
Rubber Group handles, manages and protects confidential information in an appropriatemanner according to all applicable laws, regulations and corporate rules.
As employees of the Sumitomo Rubber Group, we are expected to practice the following.

－When handling trade secrets, information about customers and business partners and otherconfidential information in the possession of Group companies, we must exercise particularcare to ensure that we do not engage in any of the following irresponsible behaviors.
・Improperly managing or storing such information in a setting where anyone can access it
freely.
・Disclosing or leaking information not (yet) intended for public release to any other party(either inside or outside of our Group) without a legitimate reason to do so.
・Using such information for private purposes.
・Duplicating, revising, altering or disposing of such information without a legitimate reason
to do so.
・Disposing of information that is no longer necessary without following proper disposal
procedures.
－We also need to be careful when it comes to the security of devices used to store andhandle information, as well as conversations in public spaces.

Ⅱ－ 3 Fair Competition
The Sumitomo Rubber Group shall fully abide by all laws, regulations and rules concerning
fair competitive practices that apply not only in Japan, but in each country and region of
the world in which we operate.
As employees of the Sumitomo Rubber Group, we are expected to practice the following.

－We must not collude with other companies in our industry or enter into unlawfularrangements (such as cartels, price fixing, etc.) for the purpose of unfairly influencing
product pricing, market shares or sales territories or otherwise impeding the free and open
business activities of any entity.
－We must not dictate product (retail) sales prices or attempt to coerce customers orbusiness partners to maintain product (retail) sales prices at a certain level (i.e. resale pricemaintenance).
－We must not engage in price setting that discriminates against specific customers orbusiness partners or attempt to shut out competitors through underselling (dumping) or
refusal to do business with specific parties, etc.
－We must not make false or misleading representations in product displays, catalogs oradvertisements (including online advertisements) or engage in false advertising that may
potentially mislead customers about products or services or otherwise engage in any activity
that violates the Act against Unjustifiable Premiums and Misleading Representations.
－When providing products and services, we must not substitute or conflate these with the
products or services of another party, imitate the appearance or labeling of other products,
make misleading representations concerning product quality, etc. or otherwise engage inany activity that violates the Unfair Competition Prevention Act.

－By law, information about Group employees is also considered to be personal informationand is therefore treated as equivalent to the personal information of customers or otheroutside parties. As such, we must not handle personal information in an inappropriatemanner even when the personal information in question concerns our own employees.
－When we retire, we must return to the company any and all documents or recording media,
etc. in our care containing any secret information. Further, our duty of confidentiality
remains in effect in perpetuity, even after our retirement.
－Anyone who has illegitimately obtained or disclosed secret information may be subject legal
consequences, including penalties, fines and/or imprisonment.

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Ⅱ Engaging in Business Activities

Ⅱ－ 4 Dealings with Contractors & Suppliers
The Sumitomo Rubber Group shall fully abide by all laws, regulations and rules
concerning procurement practices that apply not only in Japan, but in each country andregion of the world in which we operate. At the same time, we shall always strive toensure that our business dealings with suppliers and contractors are fair and aboveboard.
Further, through our procurement activities, we shall also work together with suppliersand contractors in ongoing efforts to fulfill our corporate social responsibilities.
In addition, the Sumitomo Rubber Group shall actively select suppliers and contractors
who demonstrate superior safety, quality, pricing, delivery and supply stability, who fully
abide by all applicable laws, regulations and social norms and who give due consideration
to human rights, labor rights, safety, health and the environment.

Ⅱ－ 5 Protection of Intellectual Property
Considering intellectual property to be an important asset for our business, the Sumitomo
Rubber Group encourages and promotes the creation of new intellectual property while
striving to appropriately protect and effectively utilize existing intellectual property. Further,
we shall not in any way infringe upon the intellectual property rights of any other entity.
▪In the event of infringement of the intellectual property rights of the Sumitomo RubberGroup by some outside party, we shall act to protect our intellectual property by asserting
our intellectual property rights according to the procedures prescribed by law and in amanner that is consistent with fair practices and accepted social norms.

As employees of the Sumitomo Rubber Group, we are expected to practice the following.

▪The Sumitomo Rubber Group shall provide appropriate compensation to employees who havecreated new intellectual property in the course of their work upon acquiring the rights to said
intellectual property. Please notify the company of any new intellectual property that has beencreated in the course of your work without delay while being mindful of your duty of confidentiality.

－We must engage in business dealings with suppliers and contractors on an equal footing
and must not attempt to force unfair trade terms, demand unfair discounts or unreasonably
restrict business dealings between a contractor/supplier and any third party, etc.

▪Employees of Sumitomo Rubber Group companies are entitled to the following types ofcompensation as consideration for inventions or other new intellectual property that they
have created in the course of their work.

－We must not unjustly reduce or delay payments to contractors or suppliers or makeunreasonable demands for price cuts, etc.
－We must not take advantage of our position to extract some personal benefit or utility fromcontractors or suppliers.
－We must verify that suppliers and contractors take sufficient consideration when it comesto preventing human rights abuses, human trafficking, child labor, forced labor, the use of
conflict minerals, environmental destruction, corruption and so forth.
－When selecting contractors or suppliers, we must do so based on fair and equitable criteria
while disregarding any particular personal connections or prejudices.

(1) Application Compensation(3) Performance Compensation(2) Registration Compensation(4) Knowhow Compensation

As employees of the Sumitomo Rubber Group, we are expected to practice the following.

－We are expected to respect the intellectual property (and inherent right to benefit from said
intellectual property) of other parties arising out of their inventions, writings or designs,
etc. As such, we must not manufacture, sell, import or export any product that imitates thedesign of another party’s product or that uses product labeling that is identical or similar
to the labeling that another party already uses on products or other business materials.
Further, we must not otherwise infringe upon the intellectual property rights of any otherparty or engage in any unfair competitive practices.
－We must not employ illegitimate means to obtain from another party any trade secrets orother valuable data that can be utilized to enhance the value of products or services (i.e.
limited disclosure data).
－We must exercise sufficient caution to ensure that the trade secrets and limited disclosure dataof other parties has not been obtained through illegitimate means or unauthorized disclosure.
We must not obtain, use or disclose any information that has been obtained through illegitimate
means or unauthorized disclosure, regardless of whether directly or indirectly.
－Where the trade secrets of another party have been legitimately obtained based on theterms of a contract, said trade secrets must be used in accordance with the provisionsof said contract and managed in an appropriate manner to prevent unauthorized use or
disclosure to outside parties.

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Ⅱ－ 6 Export ControlsⅡ－ 7 Restrictions on Entertaining, Gifts, Donations, Etc.

In the interests of maintaining the peace and security of the international community, theSumitomo Rubber Group shall practice strict export controls in accordance with various
laws, regulations and treaties concerning international trade.

The Sumitomo Rubber Group shall not engage in any actions or behaviors that go beyond
the realm of generally accepted business practices when it comes to entertaining, gifts,
donations or the provision of other forms of benefit or utility.

※ W hen exporting products or sharing or licensing technologies that could potentially be used in thedevelopment or manufacture of nuclear materials, nuclear weapons, chemical weapons or other weaponsof mass destruction, etc. to foreign entities, it is first necessary to obtain the permission of the competentauthorities by following the procedures prescribed by various laws, regulations and treaties concerninginternational trade.

As employees of the Sumitomo Rubber Group, we are expected to practice the following.

As employees of the Sumitomo Rubber Group, we are expected to practice the following.

－W hile the Sumitomo Rubber Group does not currently (as of July 2022) produce any
products or technologies that could directly be used in the development or manufactureof nuclear weapons or other weapons of mass destruction, it is still necessary to apply tothe competent authorities for export authorization where required by applicable laws or
regulations.

－When providing entertainment or gifts, etc. to customers or making donations, we must firstcomplete the requisite internal procedures as dictated by the company and must not exceed
the realm of generally accepted business practices.
－We must not accept from suppliers any expensive gifts, excessive entertainment or otherforms of benefit or utility beyond the realm of generally accepted business practices. Pleasebe sure to consult with your superiors if you have been offered excessive entertainment or
expensive gifts.

－When exporting equipment or machinery that is not a product of the Sumitomo Rubber Group,
please be sure to obtain documentation from the manufacturer or supplier attesting to the factthat the equipment or machinery in question is not subject to export controls. Having doneso, please then check with the competent authorities as to whether export authorization isnecessary nevertheless. (Particular caution is needed here, as even individual components of apiece of equipment or machinery may be subject to export controls.)－Please also exercise caution with regard to exports originating outside of Japan, as the same
controls that apply to exports from Japan also apply to exports between companies of theSumitomo Rubber Group outside of Japan.
－Failure to fully abide by laws and regulations concerning import and export controls may
result in serious legal consequences, including steep fines and/or imprisonment, etc.
As import and export controls vary from country to country and are frequently revised,please be sure to contact the Legal Affairs Department should you have any questions or
uncertainties concerning exports.
※ About OFAC ControlsIn order to accomplish objectives with respect to foreign policy and national security, the United States
imposes and enforces sanctions (including prohibitions against transactions and the freezing of assets)
against designated persons and organizations, such as government agencies and state-owned corporations
in countries that are subject to UN sanctions or US embargoes, state sponsors of terrorism and so forth.
Any transaction that is denominated in US dollars, regardless of where in the world it takes place, ispotentially subject to these sanctions, which are known as OFAC Controls. Where a business partner(supplier, customer, etc.) is subject to OFAC Controls (or where there is a strong suspicion that a business
partner may be subject to OFAC Controls), transactions with said business partner may be impeded, as
payment processing may not proceed smoothly, and payments may even be frozen as the assets of asanctioned individual or organization. The United States Treasury Department publishes a list of persons
and organizations who are subject to OFAC Controls, called the SDN List (Specially Designated Nationals
and Blocked Persons List). Thus, it is important to check the SDN List prior to engaging in transactions withbusiness partners (and especially new business partners) who may potentially be subject to OFAC Controls.

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Ⅱ－ 8 Relations with Public Officials
The Sumitomo Rubber Group strictly prohibits the provision of entertainment and gifts
to public servants in Japan and overseas (including those whose work descriptions andresponsibilities make them de facto public servants).
▪The Sumitomo Rubber Group prohibits small-sum facilitation payments except where theseare explicitly permitted in accordance with the laws or regulations of the country or region inwhich they occur.
※ Facilitation payments are small-sum payments intended to facilitate or expedite the procedures entailed
in the provision of certain administrative services.

As employees of the Sumitomo Rubber Group, we are expected to practice the following.

－We must not provide illicit benefit, utility, entertainment or gifts, etc. to employees orformer employees of government agencies, local public entities or other public institutions,regardless of whether in Japan or overseas.
－Notwithstanding the above, please prioritize personal safety in cases where refusal to follow
the demands of a public servant may potentially result in bodily harm or loss of life.
－It is also against the law to provide illicit benefit, utility, entertainment or gifts to public
servants through the offices of a consultant, agent or other intermediary. Further, evenin cases where a consultant, etc. has used payments received from the company to fundthe provision of illicit benefit, utility, entertainment or gifts to public servants at his or hersole discretion, any employees involved with said consultant, etc. still run the risk of being
charged and punished as accomplices.
Thus, it is particularly necessary to pay attention to the following points.
・Is the consultant, etc. demanding payment of excessive consulting fees?
・Are the actual contents of services to be provided clearly stated in a contract?

Ⅱ－ 9 Timely Disclosure of Information
In the interests of ensuring corporate accountability with respect to our shareholders,investors and other stakeholders, the Sumitomo Rubber Group shall provide reliable,
accurate and transparent information concerning the material facts of our management
philosophy, business policies, financial situation, business activities and other general
corporate activities to securities exchanges in a timely manner. Further, we shall respondto outside inquiries concerning the information that we have disclosed in a manner thatis prompt and appropriate while complying with the applicable regulations enacted
pursuant to the Financial Instruments and Exchange Act (including Fair Disclosure
Regulations and Insider Trading Regulations).
As employees of the Sumitomo Rubber Group, we are expected to practice the following.

－With the exception of information for which we are bound by a duty of confidentiality or
information that is generally considered to fall under the category of trade secrets, we shallgenerally disclose accurate and timely information concerning our corporate management
and business activities in line with the contents of our consolidated financial statements.
－We shall respond to external requests for the disclosure of information in good faith,handling inquiries and press relations based on the following lines of thinking.
・Do not refuse such requests without a valid reason to do so.
・Do not say anything that contradicts the facts.
・Clearly state that you are unable to disclose certain information if this is the case.
・Do not disclose different information or respond differently to different individuals.
－Please notify the Public Relations Department of any external inquiries or requests fromjournalists.

・Does the consultant, etc. have any relatives or close friends who are public servants?
－Where a public servant has demanded a bribe or some other form of illicit benefit, please
promptly report the situation to your superiors or the Corporate Ethics Helpline (Compliance
Consultation Office).

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Ⅱ－10 Prohibition Against Insider Trading
The Sumitomo Rubber Group strictly prohibits actions that impinge upon the fairnessof securities markets through the misuse of insider information (about either Group
companies or other companies) that we have learned in the course of our work.
※ The term “insider information” refers to important corporate information that has not (yet) been disclosed
to the public and that would influence the investment decisions of investors if known, such as information
concerning products, finances, capital flow, business partnerships and so forth.

As employees of the Sumitomo Rubber Group, we are expected to practice the following.

－We must not disclose any insider information that we have learned in the course of our work
to any party (regardless of whether inside or outside of our Group) until said information ismade available to the public.
－We must not engage in insider trading after learning insider information about either
Group companies or other companies in the course of our work. This means that
we must refrain from buying or selling stocks or other securities in the companies
in question until said information is made available to the public. This rule also
applies to securities trades carried out by our family members, relatives and friends.
Please understand that insider trading and the illicit sharing of insider information is against
the law (in Japan, insider information and insider trading are subject to the Financial
Instruments and Exchange Act). Violations are subject to legal consequences, including
surcharges, fines and/or imprisonment.

Ⅲ Relationship Between Company & Society

Ⅲ－ 1 Abiding by Laws & Social Norms
The Sumitomo Rubber Group shall uphold and fully abide by all applicable laws,
regulations and social norms.

As employees of the Sumitomo Rubber Group, we are expected to practice the following.

－As we go about our day-to-day work, we should always keep in mind the fact that thecontinuation of our business activities is premised on our compliance with all applicablelaws, regulations and social norms.
－We should listen to criticism or other opinions from society at large with humility andrespond in an appropriate manner, such as by working in good faith to make improvements.
－As we are directly involved in the automotive industry, we bear a particular responsibility
to obey traffic rules, to drive in a manner that sets an example for others and to actively
promote traffic safety in general.
－We shall obey the tax laws in each country and region of the world in which we operate aswell as international tax rules, both in letter and in spirit. As such, we shall pay the taxes that
we owe when they are due.

－Those working in sections or departments that handle insider information must exercise
sufficient caution in the handling of said information so that unauthorized personnel do nothave access to insider information.

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Ⅲ Relationship Between Company & Society

Ⅲ－ 2 Dealing with Antisocial Forces
The Sumitomo Rubber Group takes a strict stance against organized crime and other
antisocial forces, staunchly refusing all business dealings and other relations with
antisocial forces. Further, we do not in any way, shape or form fund, employ or allow
ourselves to be intimidated by antisocial forces.
※ “Antisocial forces” is a blanket term for organizations and individuals who employ violence, threats and various
fraudulent means to pursue illicit financial gain. Antisocial forces include gangs, front companies associatedwith gangs, extortionists who disrupt (or threaten to disrupt) general meetings of shareholders, racketeers who
operate under the guise of social or political activism, organized crime syndicates and so forth.

▪The Sumitomo Rubber Group takes an organizational approach to dealing with antisocial
forces. Our basic stance is to present a united front in responding to any and all demands
from antisocial forces by staunchly refusing to cooperate with any such demands, contacting
the police at the first sign of potential trouble and fully cooperating with police thereafter.
Upon receiving a report of demands or any other contact from antisocial forces, we shallwork to ensure the safety of our employees through a comprehensive organizational
response that involves close cooperation and coordination with police, attorneys, specialized
agencies and other experts both inside and outside of our Group.

Ⅲ－ 3 Involvement in Politics
The Sumitomo Rubber Group shall fully abide by all applicable laws, regulations andrules concerning the political activities of corporations.

As employees of the Sumitomo Rubber Group, we are expected to practice the following.

－E xcept where explicitly permitted by applicable laws and regulations, we must not
make political donations or participate in political campaigns for politicians or politicalorganizations who have some direct connection with our business activities.
－If requested to participate in a political campaign on the corporate level (i.e. as a corporate
representative), please contact the Human Resources & General Affairs Department andrespond according to the instructions that they provide.

▪As a general rule, the Sumitomo Rubber Group includes a standard clause concerning theelimination of antisocial forces in all contracts that we conclude so that we may immediately
cease transactions and terminate contracts with business partners (suppliers, customers,etc.) who are found to have any form of involvement with antisocial forces.
As employees of the Sumitomo Rubber Group, we are expected to practice the following.

－We are required to promptly report any contact that we have with antisocial forces to oursuperiors, who are then required to contact the Legal Affairs Department or the Human
Resources & General Affairs Department.
－We need to pay particular attention to the following points in order to ensure that we do not
become involved in money laundering.
・Business partners who insist on payments in cash or cash equivalents.
・Payments from third parties who have no involvement in the business dealings in question
or from bank accounts that are not usually used in the course of normal business dealings.
・Business partners who demand that payments be divided into multiple small-sum payments.
・Business partners who are hesitant to provide information or who provide inaccurate information.
・Business partners who are listed on the SDN List or other similar lists.

※ Money laundering is the process of obscuring the origin (source) of illicit gains from drug deals, tax
evasion, fraudulent accounting or other criminal activity by means of using multiple anonymous bankaccounts and/or bank accounts under false names to shuffle illicit funds between several financial
institutions or by repeatedly trading financial instruments, etc.
※ Issued by the US Treasury Department, the SDN List (Specially Designated Nationals and Blocked Persons
List) is a list of sanctioned individuals and organizations, such as government agencies and state-owned
corporations in countries that are subject to UN sanctions or US embargoes, state sponsors of terrorism
and so forth.

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Ⅲ－ 4 Sustainability Efforts

Ⅲ－ 5 Abiding by Local Rules in Each Country

Based on our Basic Philosophy for Sustainability Activities, the Sumitomo Rubber Groupaims to be a corporate group that earns the trust of society at large through businessactivities that actively contribute to the solution of various social issues in order tomove toward the realization of a sustainable society.

With an awareness of our position as a member of the international community, theSumitomo Rubber Group and our employees shall ensure that we properly understandand fully abide by the rules of each country and region in which we operate.

▪The globalization of our business has led to the diversification of our stakeholders, who are
now spread out across the world. In order to earn the trust of all of our many stakeholders,
it is essential that we always strive to engage in business activities that are honest andaboveboard.

As employees of the Sumitomo Rubber Group, we are expected to practice the following.

▪In addition to abiding by all applicable laws and regulations, the Sumitomo Rubber Groupalso strives to minimize the environmental impact of our products, services and overallbusiness activities as much as possible.
▪In the interests of improving the sustainability of our business activities, the Sumitomo
Rubber Group shall work to promote environmental activities that account for biodiversity,
uphold human rights, create a wholesome work environment, prioritize safety and health,augment our corporate governance and so forth.
As employees of the Sumitomo Rubber Group, we are expected to practice the following.

－We should all actively engage in various activities as upstanding members of our local
communities so that communities will come to welcome and trust the Sumitomo RubberGroup.

－Social values can vary greatly between countries and regions. As such, it is essential that we
not only have a sufficient understanding of local laws and social conditions, but also engage
in business activities that give ample consideration to local cultures, customs, religious
beliefs and so forth.
－In the interests of fostering greater mutual understanding, the Sumitomo Rubber Groupencourages and supports cultural and social activities undertaken by our overseas
subsidiaries and the employees thereof while actively promoting closer communication
among our employees throughout the world.
－We must not provide any illicit benefit, utility, entertainment or gifts to public servants inforeign countries, regardless of local customs.
※ Legal Extraterritoriality

In some cases, the laws and regulations of one’s own country may apply to actions carried out overseas
or business dealings involving corporations that operate in foreign countries. For example, when US
authorities discovered that another company in our industry had engaged in bribery in various countries
throughout Latin America, they imposed hefty fines against that company, even though the bribery hadtaken place overseas (because the company also operated in the United States).
As extraterritorial laws are especially likely to apply in cases involving fair competition, corruption,
security trade controls and money laundering, employees of the Sumitomo Rubber Group must exercise
particular caution not only when it comes to following local laws, but also to avoid potential violations of
extraterritorial laws.

Should you have any questions about the contents of this Code of Conduct as they
relate to your actual work, please consult with your superiors, the Legal Affairs
Department, the Human Resources & General Affairs Department, the Intellectual
Property Department or other related departments before engaging in any action
about which you are unsure.

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