Showa Denko Group’s Global Anti-Bribery Policy

1.Basic Policy

The Showa Denko Group hereby proclaims “Showa Denko Group’s Global Anti-BriberyPolicy” (hereinafter “this Global Policy”) as the Group’s basic policy to prevent activitiesthat lead to formation of corrupt relationship between the Showa Denko Group andgovernment officials or the authorities concerned, including bribery and the compulsion,offer and inducement to bribe. By practicing this Global Policy, the Showa DenkoGroup shall perform fair and sound business activities, thereby becoming a globalcorporate group that contributes to sustainable growth of society.

2.Applicability of this Global Policy

This Global Policy is applied to all executives and employees of the Showa DenkoGroup (including contract employees, part-time employees and temporary workersfrom agencies) (hereinafter “staff”).

3.Compliance

The Showa Denko Group and its staff shall observe all applicable laws and regulationsconcerning prevention of bribery.

4.Prohibited Activities

  1. 1)The Showa Denko Group and its staff shall not bribe, offer to bribe or promise tobribe directly or indirectly any public official of any country (including, but not limitedto, the staff of companies substantially controlled by national or local government,the staff of international public agencies, candidates for public positions and quasi-public servants) or any staff of any private enterprise with money or other economicreturns for the purpose of making receivers or potential receivers of bribes to actin connection with their duties in order to realize illegal business profits oradvantages.
  2. 2)The Showa Denko Group and its staff shall not directly or indirectly receive, request,or promise to receive money or other economic returns with which the givers bribethe receivers to provide illegal business profits or advantages correlated with thereceivers’ businesses or jobs.

5.Audit and Contact Offices for Whistle-blowers

The Showa Denko Group shall seek early detection of conduct which is suspected of breaching this Global Policy or violating laws to prevent briberies through periodic audits and just and fair operation of contact offices for whistle-blowers.

6. Response to Emergency

If conduct which is suspected of breaching this Global Policy or violation of laws to prevent briberies is detected in the Showa Denko Group’s business processes, the Group and its staff shall report the situation to relevant organizations and persons in accordance with internal regulations, and take appropriate actions to handle the situation, including cooperation with the relevant authorities on investigation.

7. Record Keeping

The Showa Denko Group shall observe internal regulations concerning record keeping, put any transaction on record in a timely and accurate manner, and keep accurate and systematic records.

8. Disciplinary Action

If a member of staff of the Showa Denko Group acts contrary to this Global Policy, the Group shall take disciplinary action against the member in accordance with Employee Regulations and other relevant internal regulations.

9. Amendment

The Showa Denko Group shall continuously review its system to prevent bribery and corruption, including this Global Policy, and improve it when necessary.

[Record]
Establishment: January15, 2019

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