Status of the Development of the Internal Control System

Sumitomo Chemical established its Basic Policy for the Enhancement of the Internal Control System by a resolution of the Board of Directors, creating a system to ensure the appropriateness of its operations as stipulated in the Companies Act.

As stated in the basic concept of this policy, we recognize that the development of an internal control system is a necessary process for maintaining a sound organization and should be actively utilized to achieve business objectives. To continuously enhance our internal control system, we have formed the Internal Control Committee, which is chaired by the President and consists of Executive Officers responsible for and in charge of each business sector and corporate department. Regular meetings of the committee are held three times a year.

At Sumitomo Chemical, the Internal Control Committee plays a central role in discussing various measures based on the basic policy described above. The committee also operates a PDCA (plan-do-check-act) cycle by monitoring the implementation status of those measures, and constantly inspects and strengthens the Group’s internal control system in response to changes in the Group’s business and operating environment, so that the Group’s internal control system can function effectively.

The Standing Corporate Auditors attend the committee as observers, and the committee’s operations are conducted by the Internal Control & Audit Department, independent of other business activities. Summaries of the matters covered in the committee are reported to the Board of Corporate Auditors after each meeting. These summaries are then reported to the Board of Directors for deliberation.

Internal Control Committee

The Internal Structure Regarding Timely Disclosure

The Corporate Communications Department is in charge of working in conjunction with other relevant departments to continually disclose necessary information in a timely manner. In addition to items requiring disclosure under Japan’s Financial Instruments and Exchange Act and under stock exchange regulations, we also actively disclose information that may be considered material to the decisions of investors. We endeavor to build stronger relationships of trust with society and capital markets by publishing documentation in accordance with the rules stipulated by the security exchanges in Japan, including reports on the Company’s corporate governance philosophy and system, and notifications showing that Outside Directors and Audit & Supervisory Board Members have no existing conflicts of interest with general shareholders. These documents are available on the website of Japan Exchange Group Inc.

Internal Audits

As part of its internal control monitoring activities, Sumitomo Chemical has established a dedicated organization within the Company to conduct internal audits, in addition to audits by the Corporate Auditor and Financial Statement auditors. The Internal Control & Audit Department conducts internal audits for all matters related to the execution of operations by the Company and its Group companies, and dedicated audit teams for the Responsible Care Department conduct responsible care auditing from the perspective of safety, health and environment, and quality throughout the life cycle of chemical products. Internal audits and responsible care audits are coordinated with each other as needed. Furthermore, the selection of the general manager of the Internal Control & Audit Department and the general manager of the Responsible Care Department must both be put before the Board of Directors for resolution.
In case any serious matter relating to internal controls is found, the matter will be promptly reported to the Executive Officer of the relevant reporting line and the Board of Corporate Auditors (or in the event of a finding concerning senior management, to the Board of Corporate Auditors and the Executive Director of the Compliance Committee).

(1) Internal Audits

Department Conducting the Audits	Internal Control & Audit Department
Objective of Internal Audit	Evaluate whether internal controls are in place, operating, and functioning appropriately from various perspectives, including maintaining the effectiveness and efficiency of operations, ensuring the reliability of financial reporting, and complying with relevant laws and statutes in all business activities
Audit Cycle	In principle, once every 2 - 5 years for each separately audited unit
FY2022 Number of Companies and Organizations Conducting the Audits	Business process audits: 12 in-house organizations, 5 Group companies in Japan, 17 Group companies overseas Information system security audits: 3 in-house organizations; 5 Group companies in Japan, 9 Group companies overseas
Sharing of Audit Results and Status of Improvements	Reported to the Internal Audit Liaison Meeting (Held regularly, four times a year, attended by Standing Audit ＆ Supervisory Board Members and a number of departments, including the Internal Control & Audit Department, the Responsible Care Department, the Legal Department, the Human Resources Department, the Accounting Department, and the planning & coordination offices of each business sector) After reporting at the Internal Control Committee (held three times a year), the report is reported to the Board of Audit & Supervisory Board Members and the Board of Directors.

(2) Responsible Care Audits

Department Conducting the Audits	Teams of dedicated auditors from the Responsible Care Department
Objective of Internal Audit	Evaluate whether internal controls relating to securing safety, health and environment, as well as maintaining and improving quality for all chemical products over their lifecycle, are in place, operating, and functioning appropriately.
Audit Cycle	In principle, once every 1 - 3 years for each separately audited unit
FY2022 Number of Companies and Organizations Conducting the Audits	12 in-house organizations, 21 Group companies in Japan, 12 Group companies overseas
Sharing of Audit Results and Status of Improvements	Reported internally as necessary Reported to the Responsible Care Committee (Held regularly, once a year)