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Basic Rules to Comply With

Sumitomo Chemical requests every Employee and Board member to comply with the guidelines outlined below and has distributed to each of them a Compliance Manual that provides information on major relevant laws, regulations and company rules to observe.

Rules concerning the Company and the Company's Assets

Compliance with the Company's Employee Work Regulations

You must comply with the Company's Employee Work Regulations and other human resources and personnel management-related rules.

Prohibition on canvassing for membership of political parties, religious organizations, etc.

You must not force other persons or undertake canvassing activities for them to join or support a particular political party, religious organization or other organizations that people should select to join or not to join based on their personal beliefs or preferences.

Proper accounting treatment

The Company must adopt generally accepted accounting standards.

Proper keeping of transaction records

You must accurately record transactions relating to the activities of the Company and properly keep relevant records.

Control of trade secrets

Confidential information, such as customer information, trade secrets, or know-how, is an important asset of the Company. Therefore, you must undertake the necessary actions to protect such confidential information. In addition, you must respect the confidentiality of information obtained from third parties and must undertake the same protective actions about such information.

Proper treatment of corporate assets (including intellectual property rights)

You must record all corporate assets, whether they are tangible or intangible, and properly use and control them.

Prohibition on conflicts of interest

You must not perform any activities that may impair the interests of the Company by taking advantage of your position in the Company or by exploiting information that you come to know during the course of your business activities. Without obtaining the prior permission of the Company, you must neither perform any activity nor assume any position that is likely to be in conflict with the interests of our Company.

Prohibition on the inappropriate use of corporate assets

You must not use corporate assets (either tangible or intangible) for any purpose other than that of our Company's business activities.

Proper use of computer system

You must not use the computer systems of our Company for illegal or other improper purposes. In addition, you must take the pre-determined measures to prevent information therein from leakage, etc.