Sumitomo Bakelite Co., Ltd.

Business Philosophy and Code of Conduct

Business Philosophy

"Business Philosophy" for the Group of Sumitomo Bakelite Co., Ltd. is as follows:

Business Philosophy

Our company places prime importance on trust and sureness, and shall commit itself to contributing to the progress of society and enhancement of people’s welfare and livelihood through its business activities.

This Business Philosophy is in line with the abovementioned Sumitomo Group's Business Philosophy, and this Business Philosophy connotes the followings:

1. We value trust and confidence of all concerned and endeavor to meet all the expectations given to us as an entity under the name of Sumitomo.
2. We take steadfast steps in managing our Group without pursuing speculative profit.
3. We contribute to make a better society and improve people's quality of life through our business activities of research, development, production and sales of creative and innovative plastics.

Our Code of Conduct

Our group has the following "Our Code of Conduct" as a code of conduct for conducting business activities with integrity.

Our Code of Conduct (Established：January 1998, Updated：July 2022)

1. We contribute to the realization of a sustainable society and provide products and services that satisfy our customers.
2. We conduct fair and transparent business activities in accordance with laws, regulations and corporate ethics.
3. We are committed to creating a safe working environment and maintaining and promoting good health.
4. We actively promote efforts to preserve the global environment.
5. We respect the human rights of all those involved in our group's business.

This "Our Code of Conduct" helps our group's directors, officers and employees conduct its business activities without any wrongdoing.

Code of Ethics for Group of Sumitomo Bakelite Co., Ltd.

Based on our group's "Business Philosophy" and "Our Code of Conduct", our group has "Code of Ethics for Group of Sumitomo Bakelite Co., Ltd." as a specific standard of conduct to be observed by our group’s directors, officers and employees in the course of business.

This Code of Ethics is available in eight languages, and is used for compliance training and raising awareness of our Group’s directors, officers, and employees when they join the company and during "Compliance Emphasis Month" in October each year.

The "Code of Ethics for Group of Sumitomo Bakelite Co., Ltd." was established after approval by our Sustainability Promotion Committee and reporting to our Board of Directors. We plan to continue to periodically check the contents at the Sustainability Promotion Committee and the Board of Directors, and revise the contents as necessary.

Code of Ethics for Group of Sumitomo Bakelite Co., Ltd. (Established：June 2022)

I Product and Service Responsibilities (+ Responsibilities to Business Partners)

I-1 Appropriate Quality Control

  • We will develop, produce, inspect, and ship products in accordance with the procedures stipulated by laws and internal rules.
  • We will not ship products that do not conform to predetermined specifications. Additionally, we will not use raw materials that do not conform to predetermined specifications.

I-2 Prohibition of Data Falsification and Data Fabrication

  • We will not falsify numerical values and data related to quality, performance, and safety, or any other numerical values and data acquired in the course of business, nor will we fabricate such numerical values and data that have not been acquired in reality as if we have acquired them.

I-3 Fair and Appropriate Labeling and Representation

  • We will use fair and appropriate labeling and representation in accordance with laws, regulations, and public order and morals, and we will eliminate any inappropriate labeling and representations that may mislead our customers in their perception of facts and in their proper selecting of products and services from catalogs and technical materials related to our company and product/service.

I-4 Understanding and Compliance with Licensing Procedures

  • If we have an obligation to obtain licenses or approvals from government agencies and/or make notifications, reports, etc. to government agencies, we will ensure our understanding of the contents and procedures concerning the applicable licenses and approvals, notifications, reports, etc., and fully comply with them.

I-5 Prompt and Appropriate Response to Problems

  • In the unlikely event that a problem arises with the safety of our group's products or services, we will put the safety and health of end users first and, in cooperation with our business partners, take all possible measures promptly to prevent the occurrence or spread of accidents.

Ⅱ Human Rights and Work Environment Responsibilities (+ Responsibilities to Business Partners)

Ⅱ-1 Prohibition of Discrimination

  • We will not discriminate in any way based on sex, age, nationality, ethnicity, race, religion, ideology or creed, sexual orientation or gender identity, or disability. We also do not tolerate such discrimination.

Ⅱ-2 Prohibition of Harassment and Violence

  • We will not engage in harassment or behavior that hurts others, whether mentally or physically. We also do not tolerate such harassment or hurtful behavior.

Ⅱ-3 Prohibition of Child Labor and Forced Labor

  • We will comply with the employment laws and regulations of each country or region. We will not engage in “child labor,” i.e. the act of having those under the minimum working age stipulated by laws and regulations of the country or region in which we are located, or “forced labor,” i.e. work done against the will of the worker. We will not tolerate child labor or forced labor.

Ⅱ-4 Creating a Comfortable Workplace

  • We will appropriately manage and record working hours, holidays, and vacations in accordance with laws, regulations, and work regulations.
  • We will seek to maintain and improve good labor-management relations, and work together to create a comfortable workplace.
  • We will respect the culture and values of each country and region, and we will be considerate of religious events, customs, and so on.
  • At each workplace, we will strive to create an environment in which employees can freely and openly express their opinions on the execution of duties, human resource development, and improvement of the workplace culture.
  • We will support the balance between work and private life (work-life balance) by enabling various working styles and utilizing various leave systems. We will also support employees who are pregnant, giving birth, raising children, or caring for family members, by giving consideration to their individual circumstances and providing support throughout the workplace.
  • We will not engage in political activities, religious proselytizing, product or service solicitations, or any other activity that is not related to our duties on company’s premises or during working hours.

Ⅱ-5 Occupational Health and Safety Management

  • We will adhere to our safety philosophy of “Safety is the first priority of all” and make our best efforts to prevent industrial accidents.
  • We will ensure our safety and the safety of our fellow workers by understanding and complying with laws and regulations concerning occupational health and safety, as well as internal rules and procedures concerning occupational health and safety management. We will also strive to ensure occupational health and safety not only for our own employees, but also for all parties concerned, including suppliers and subcontractors.

Ⅱ-6 Respect for Privacy and Protection of Personal Information

  • We will respect the privacy of individuals, recognize the importance of protecting personal information, and appropriately manage and handle personal information in accordance with laws and internal rules concerning the handling of personal information.

Ⅲ Responsibilities to Society

Ⅲ-1 Compliance with Competition Law (Antitrust Law, etc.) and Implementation of Fair and Appropriate Transactions

  • We will comply with the trade regulations of competition law (antitrust law, etc.) and engage in business activities based on fair, transparent, and free competition.
  • We will never enter into agreements or exchange information with our competitors regarding sales conditions, such as prices, quantities, shares, and customers of our products and services, which may affect free competition.
  • As a general rule, we do not contact our competitors. Even when we have a legitimate purpose for contact with competitors, such as participation in an industry association or consideration of manufacturing consignment or license, we will keep such contact with competitors to the minimum necessary and will not exchange information with them for any purpose other than the original purpose. In such cases, we will record date and time, the parties involved, the content of the conversation, and so on. Furthermore, if there are internal rules and procedures regarding contact with competitors, we will follow those rules.
  • We will not require distributors to maintain resale prices, except where permitted by law.
  • We will not abuse superior bargaining positions to make unreasonable demands of our business partners.

Ⅲ-2 Prohibition of Bribery/Restrictions on Exchange of Gifts and Entertainment

  • We will not, either directly or through third parties, such as agents, provide any bribe or conduct any provision of goods, money, or other benefits to any public officials, officers and employees of state-owned enterprises, politicians, etc. (hereinafter referred to as "public officials, etc.") for the purpose of obtaining any wrongful gain in business. If we receive a request for a bribe from public officials, etc., we will firmly refuse such requests.
  • We will ensure that the value of gifts or entertainment provided to business partners does not exceed the scope of ordinary social norms in business practices.
  • We will not demand the provision of money or other benefits from our business partners.
  • If any business partner makes an offer to provide a gift or entertainment to us and such gift or entertainment is excessive considering ordinary social norms in business practices, then we will decline such offers.
  • When we make donations or political contributions, we will follow the procedures set forth in laws and internal rules to ensure that they are not mistaken for bribery or collusion with the politics and government.

Ⅲ-3 Compliance with Export and Import Laws

  • We will comply with applicable security trade control laws and regulations and internal rules based on these laws to ensure that the goods we export and the technology we provide are not used to develop or manufacture weapons of mass destruction or conventional weapons that can be used to threaten international peace and security. In particular, we will exercise due caution with regards to whether or not the goods or technology to be exported fall under export-controlled items, and whether or not the destination, user, or use to which the goods or technology is regulated by law and regulations as a national security concern.
  • We will comply with applicable customs laws and other applicable laws and regulations when making export and import declarations, and conduct appropriate import and export procedures without making false declarations.
  • We will appropriately label products with the country of origin in accordance with the laws and regulations of the destination.

Ⅲ-4 Compliance with Money Laundering and Terrorist Financing Regulations

  • We will comply with the applicable laws and regulations that regulate money laundering and terrorist financing. We will exercise due caution in order to prevent our group from being used for money laundering or terrorist financing in the course of doing business.

Ⅲ-5 Proper Accounting and Retention of Transaction Records

  • We will create, report, and keep accurate and factual business records. We will claim expenses based on accurate records and reports.
  • We will faithfully respond to internal audits, external accounting audits, and tax investigations, and strive to provide accurate information.

Ⅲ-6 Timely and Appropriate Information Disclosure

  • We will disclose important information that may affect our financial results and corporate performance in a timely, appropriate, and accurate manner in accordance with laws, regulations, and internal rules.

Ⅲ-7 Prevention of Insider Trading

  • We will not conduct insider trading of our company's or other companies' stocks, etc. either by ourselves or through others (such as our relatives, friends etc.) from the time we become aware of undisclosed information that may have a material impact on the stock prices, etc. of our company or other companies (insider information), until the official announcement of such insider information. In addition, we will not share insider information regarding our company or other companies with any persons other than those who need to know such information to conduct our business.

Ⅳ Responsibilities Concerning Company Assets

Ⅳ-1 Restrictions on Competitive Activities and Conflict-of-Interest Transactions

  • We strive to act and make decisions in the best interests of our group in the conduct of our business. We do not engage in competitive activities or conflict-of-interest transactions that place the interests of ourselves, our relatives and friends above those of our group in the conduct of our business.
  • We will not engage in any competitive activities or conflict-of-interest transactions (typical examples include, but are not limited to, the following) without the prescribed prior approval procedures.
    Example of competitive activities:
    ・Becoming executive director, officer, employee, or consultant to one of our group's competitors or business partners
    Example of conflict-of-interest transactions:
    ・Becoming executive director, officer, employee, or consultant to one of our group’s competitors or business partners
    ・Giving work to any entity that is owned or managed, directly or indirectly, by ourselves or friends and relatives.
  • We will not receive kickbacks by giving preferential terms to our business partners or unfairly raising prices.

Ⅳ-2 Prohibition of Misappropriation of Company Assets

  • We will not use company assets (cash, deposits, securities, cash vouchers, products and raw materials, automobiles, office equipment, IT equipment, facilities equipment, etc.), whether tangible or intangible, for personal use or for any other improper use.

ⅤInformation Management Responsibilities (+ Responsibilities to Business Partners)

Ⅴ-1 Confidential Information Management and Information Security

  • We will fully respect the rights and value of both our confidential information and that disclosed to us by others.
  • We will take appropriate measures to protect confidentiality, such as entering into a confidentiality agreement, through prescribed procedures, before disclosing our own confidential information to others.
  • We will acquire confidential information to which others have rights only when it is necessary to do so in the course of our business, in a fair and appropriate manner in line with proper business practice, and we will not acquire such information by improper means.
  • We will manage and handle confidential information appropriately in compliance with laws, regulations, and internal rules so as not to damage our company or others through leaking or misuse.
  • We will exercise due caution against increasingly sophisticated cyber-attacks, and strive to use IT devices appropriately to prevent information leaks due to cyber-attacks or misuse.

Ⅴ-2 Protection of Intellectual Property and Brands

  • We will recognize intellectual property created in the course of business as a valuable management resource for our group, and we will appropriately promote the acquisition of intellectual property rights and maintain confidentiality regarding the content of inventions, know-how, etc. prior to the acquisition of such rights, based on contracts and internal rules.
  • We will appropriately use our group's company name (trade name) and product names (trademarks) owned by our group in accordance with laws, regulations and internal rules, and strive to eliminate unauthorized use of such names by third parties.
  • We will conduct prior investigations of other parties' intellectual property rights in research, development, design, production, and sales of new products and technologies in order to prevent infringement of other parties' intellectual property rights and to promote the smooth operation of business, and if there is any doubt, we will take countermeasures.
  • We will not copy, install, or use commercial software in a manner that violates the terms of the software’s license agreements. We will not make unauthorized use of third-party copyrighted materials (text, diagrams, photographs etc. in books, magazines, and websites).

Handbook on the Code of Ethics for Group of Sumitomo Bakelite Co., Ltd.

This handbook is an easy-to-read version of the “Code of Ethics for Group of Sumitomo Bakelite Co., Ltd.", with the addition of four-panel comic strips, and is available in eight languages and is used for compliance training and raising awareness of our Group’s directors, officers, and employees.

Sumitomo Business Spirit

The origin of Sumitomo Bakelite Co., Ltd. is the business of the Sumitomo family, which has a history of approximately 400 years. The "Sumitomo Business Spirit" is a spirit that has been refined by generations of Sumitomo's predecessors, based on a letter entitled "Monjuin Shiigaki", in which Masatomo Sumitomo (1585-1652), the first generation of the Sumitomo family, succinctly explained the must-do for business. The core of the "Sumitomo Business Spirit" is further expressed in the words of the following "Business Principles".

Business Principles

Article 1. Sumitomo shall achieve strength and prosperity by placing prime importance on integrity and sound management in the conduct of its business.
Article 2. Sumitomo shall manage its activities with foresight and flexibility in order to cope effectively with the changing times. Under no circumstances, however, shall it pursue easy gains or act imprudently.
(Quoted from the Sumitomo Goshi Kaisha’s administrative regulations, named “Business Principles”(1928)）

Article 1 emphasizes the utmost importance of integrity, while Article 2 advocates the importance of having an enterprising spirit to generate profits quickly and faithfully while adapting to a changing society, and renovating business operations while avoiding the pursuit of easy gains or acting carelessly.

Our group’s ”Business Philosophy”— ”Our company places prime importance on trust and sureness, and shall commit itself to contributing to the progress of society and enhancement of people’s welfare and livelihood through its business activities.”— also originates from the above-mentioned ”Sumitomo Business Spirit”.