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Material Procurement

Relationship with Business Partners

The Purchasing Headquarters exercises overall control and adjustment over the purchase in general of the prescribed raw materials, fuel, machines, and equipment installed in the buildings of the Company's plants and domestic and overseas affiliates.

Principles

When executing business operations, we endeavor to comply with the laws, regulations, and social norms at home and abroad, while asking our suppliers to do likewise. Specifically, we ask suppliers to enter into basic agreements on transactions under which both parties agree to respect human rights, assure safety and health, and protect the environment.

Material Procurement

The Company selects new suppliers to purchase from in accordance with our own internal criteria. We decide to transact business according to the required procedures after making an equitable and fair determination in light of all criteria. In addition, we think it is important to constantly build mutual ties that build confidence in our suppliers, which results brings mutual benefits to both parties.

Compliance

When starting transactions, we check to see whether our procedures fall under the Act against Delay in Payment of Subcontract Proceeds, etc., to Subcontractors. If we find that the Act applies to our procedures, we respond by bringing our procedures into compliance with the Act and the internal rules of the Company. By the same token, if the existing transactions are subject to the Act, we promptly take action to comply.

The Company has internal rules to verify whether any given raw materials are in compliance with the internal and external regulations related to chemical substances. Such substances are not adopted unless they are in compliance. If compliance is ascertained, purchase specifications including such items are drawn up. Then, the raw materials to be used will comply with the chemical substance regulations because the in-house rules do not allow them to be registered without the purchase specifications. Meanwhile, looking into the newly established rules is being worked on together with the other relevant departments inside the Company.

Audit

The Purchasing Headquarters audit all raw materials suppliers. In many cases, an audit is conducted at the same time as the Production and/or Quality departments conduct their audits. The items for audit and the criteria for determination are developed at Headquarters' option with their research focused on a stable supply. Checking on the suppliers' situations, including their companies as a whole, the applicable business, raw material procurement, equipment location, production worksites, workers, relationship with the Company, and other factors, the Purchasing Headquarters makes a comprehensive decision. If any improvements are necessary, the Company draws suppliers' attention in writing to the items requiring improvement, while requesting that they respond with a due date for the action indicated.

Procurement Policy

The group companies of Sumitomo Bakelite Co., Ltd. adhere to the following rules and principles when carrying out procurement activities, in order to accomplish our corporate social responsibility (CSR) goals, with cooperation of our suppliers.

Fair Transaction

- We select new suppliers on a fair and equitable basis.

- We work to build and maintain equal and trusting relationships with our suppliers and to conduct transactions of mutual benefit.

Stable Procurement

- We consider it important that our suppliers endeavor:
(1) to maintain a proper quality and enhance the level of technology;
(2) to keep delivery date;
(3) to price competitively; and
(4) to ensure stable supply.

- The Company will separately establish contingency plans which include rules for reducing risks involved in procurement of raw materials and for actions to be taken if these risks occur.

Corporate Social Responsibility

- We carry out CSR procurement and request our suppliers to follow suite. We deem, among others, followings are important:

(1) to prohibit inhuman treatment including discrimination, harassment, child labor and forced labor and to respect human rights of labors;
(2) to comply with laws, regulations and social norms;
(3) to ensure occupational safety and health;
(4) to conserve global environment and reduce environmental load;
(5) to exercise due diligence on the source and chain of custody of conflict minerals; and
(6) to reject relations with antisocial forces.

- We establish "Green Procurement Guideline" and carry out green procurement as an initiative for reducing environmental load.

Information Management and Control

- We proactively disclose information that is deemed necessary for transactions to an extent possible.

- We strictly control and manage information provided by our suppliers and keep it confidential as requested.

Protection of Intellectual Property Right

- We consider intellectual property rights to be one of the most important management assets and protect our own rights accordingly. Likewise, we respect the rights of others.

EICC Code of Conduct

- EICC (Electronic Industry Citizenship Coalition) Code of Conduct serves as a de facto standard to ensure that working conditions in the electronics industry supply chain are safe, that workers are treated with respect and dignity, and that business operations are environmentally responsible and conducted ethically. We are not a member of the EICC, but a large number of our customers are. Therefore, we make our best effort to comply with the EICC Code of Conduct,  when carrying out procurement activities.

- We request our suppliers to carry out their business activities in accordance with the EICC Code of Conduct.

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