Tokai Carbon Group Procurement Policy
Version 2.0

1. Introduction
Tokai Carbon Group has set a goal of “contributing to a sustainable society throughadvanced materials and solutions” in its long-term vision toward 2030. We believe thatthese activities will not solely be completed by the efforts of Tokai Carbon Group, butmore with the understanding and cooperation of our suppliers, including those of theupstream supply chain.
Based on this concept, we have revised the Group’s procurement policy, which has beenshared with our suppliers for quite a while, as Version 2.0 to more appropriately reflect
the demands of society. This procurement policy consists of a basic procurement policy
for Tokai Carbon Group and guidelines that we would like to share with our suppliers.
With this procurement policy, the Group will contribute to the realization of asustainable society with our suppliers.

12. Tokai Carbon Procurement Basic Policy
1） Partnership
Recognizing that suppliers are important partners in contributing to the realization ofa sustainable society, the Group treats suppliers on an equal and fair basis and conducts
sincere transactions with the aim of mutual development.

2） QCD and fair and impartial evaluation and selection
The Group evaluates suppliers’ efforts from a fair and impartial perspective, taking
into consideration the Quality/Cost/Delivery (delivery date and stability) of procured
goods, and stably procures the most appropriate products and services.

3） Compliance
The Group not only complies with all laws and regulations applicable in thecountries and regions where it does business, but also strives to conduct procurement
activities with integrity and in accordance with the ethics and common sense of society.

4） Respect for human rights
The Group conducts procurement activities with respect for basic human rights inaccordance with the Universal Declaration of Human Rights (UDHR), the Guiding
Principles on Business and Human Rights, and other international regulations on human2

rights, etc. such as various treaties, etc. of the International Labor Organization (ILO). If
there is a conflict between international human rights conventions, etc. and laws andregulations of a country or region, the Group seeks any way to respect the former to themaximum extent while observing the latter.

5） Coexistence with the global environment, international
community, and local communities
In order to contribute to the realization of a sustainable society, the Group gives
consideration to resource conservation and environmental impact when procuring raw
materials and parts of our products, and materials, services, etc.
Furthermore, the Group respects the culture and customs of each country and region,and seeks to build relationships of trust and coexistence, through appropriate
communication with the international and local communities.

33. Guidelines to be shared with suppliers
The Group believes that addressing social issues throughout the supply chain is
important for the realization of a sustainable society.
Therefore, we request that suppliers fully understand the following matters and work
together with the Group to comply with them. We also ask that suppliers encouragecompanies located upstream in the supply chain from which they procure to familiarize
themselves with and comply with these guidelines.

1) Sincere and fair business activities(i) Not to conduct any act that could fall under unreasonable restraint of trade
including private monopolization, cartels and bid-rigging, or unfair businesspractices such as abuse of a superior bargaining position, and to comply with thecompetition laws and various regulations of the country or region concerned.
(ii) Not to get involved, either directly or indirectly, in the giving and receiving ofmoney, excessive business entertainment, demands for such things, or any otherkind of corruption, bribery, money laundering, extortion, misappropriation,embezzlement, etc.
(iii) To carry out appropriate procedures and control of technologies, goods, etc.
restricted by laws and regulations in the countries and regions where the suppliers
do business.
(iv) We will comply with laws and regulations of each country and region concerning
safety and quality, establish and operate a company-wide system to ensure safety

4and quality, including ISO 9001 certification, and provide a stable supply of safeand high-quality products at reasonable prices.
(v) In addition to the foregoing, to comply with all laws and regulations applicable inthe countries and regions where the suppliers do business.
(vi) To encourage the upstream supply chain of raw materials, etc. to comply withlaws and regulations of each country and region, and at the same time, to strive tocollect information on products and services, etc. by tracing back to the upstream
supply chain of raw materials, etc. and manage such information appropriately. To
use their best efforts to disclose any information when so requested by us or ourcustomers, etc.

2) Respect for human rights and safe working environment
Respect for human rights(i) To respect the human rights of all people and to prohibit inhumane treatment,
including discrimination, abuse and harassment of all kinds. In addition, not totolerate human rights violations such as child labor, forced labor, slave labor andhuman trafficking in its corporate activities in all countries and regions.
(ii) To comply with labor-related laws and regulations in each country and region
regarding working conditions, working hours and wages, and strive to provide aliving wage that ensures a basic standard of living, while meeting the legal
minimum wage, with respect to wages.
(iii) To accept the rights of employees to free association and collective bargaining
based on laws of each country and region.
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(iv) In addition to the foregoing, to comply with all laws and regulations concerning
human rights applicable in the countries and regions where it does business.
(v) With regard to minerals and raw materials, etc. mined or manufactured in conflictareas, etc. (e.g., conflict minerals (tin, tungsten, tantalum, gold), cobalt, natural
rubber, etc.), those that are not related to human rights abuses, environmental
destruction, etc. shall be procured, and if there is any concern, to take measures toavoid use of such minerals, etc.
Safe working environment(i) To prioritize ensuring the health and safety of our employees in the workplace, tocomply with laws and regulations of each country and region regarding
occupational health and safety, and to create an environment that takes into
consideration the prevention of accidents and disasters.

3) Efforts to preserve the global environment; coexistence withlocal communities(i) To comply with all environmental laws and regulations applicable in the countries
and regions where it does business, and to establish a general management
scheme for promoting environmental activities.
(ii) To determine the impact that the business practices have on ecosystems, and giveconsideration to biodiversity.

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(iii) To strive to conserve resources and energy, minimize waste, reduce emissions
causing global warming and toxic substances, use water efficiently, and properly
manage wastewater.
(iv) To respect the culture, customs, etc. of the local community, and to contribute to thehealthy development of the community through appropriate communication andharmonious coexistence.

4) Appropriate disclosure of corporate information(i) To provide necessary information to stakeholders in a timely and appropriatemanner, and strive to maintain sound relationships with them.

5) Protection of company assets and information(i) To properly protect and manage internal and external confidential and personal
information in compliance with laws and regulations of each country and region
regarding information management and internal rules, and to use such information
only for appropriate purposes.

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