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Expending Assiduous Efforts for Bribery Prevention

As corporations expand activities across national boundaries, promoting fair competition becomes increasingly important in the supply of goods and services in the international marketplace. Being evident from the ever tightening of laws and regulations in the world geared to prevent corruption, such as the FCPA in the U.S. and the Bribery Act 2010 in the U.K., there is a growing awareness globally that corrupt conduct, such as bribery, should be eliminated by all means. Under the circumstances, Sumitomo Chemical views bribery prevention to be one of its most vital initiatives to advance in ensuring compliance, and is devoting unwavering efforts to further strengthen its internal organization to this end as well as working to create a sustainable sound corporate climate in which everyone shares the common perception of no single compliance violation being tolerated.

Specifically, we have taken a number of concrete measures and continue to do more in the future that would help prevent any conduct which might lead to bribery if left unchecked. They include defining relevant internal rules more strictly, tightening the Company's modus operandi in various business practices, including setting stricter internal authorization procedures to put such efforts into practice effectively, providing a Compliance Manual for Bribery Prevention to all employees as guidelines of business conduct for preventing bribery as well as carrying out educational programs for employees and Board members.

These initiatives also extend to companies of Sumitomo Chemical Group in Japan and elsewhere in the world. Sumitomo Chemical works closely with Regional Legal & Compliance Office in each Region and, where necessary, receiving assistance from local lawyers or other experts to have bribery prevention activities enhanced at every Group company, such as adopting a compliance manual for bribery prevention tailored to each Region and conducting training seminars about bribery prevention.