California Transparency Statement

At Sumitomo Rubber USA, LLC (“Company”, “we”, “our”), we recognize that our most valuable asset is our reputation for integrity, fairness, and compliance with the laws and regulations affecting our business. This recognition includes the acknowledgement of, and support for, the goals of the California Transparency in Supply Chains Act of 2010, which promote a work environment free from human trafficking and slavery.

Accordingly, we oppose any use of slavery or human trafficking in the manufacture and distribution of our products and fully support the promotion of ethical and lawful employment practices within our workplace, where all employees and suppliers are expected to abide by these same principles. Over time, we will develop and clarify these policies and procedures to include, at a minimum:

• Disclosing on our website our policy and actions against slavery and human trafficking;
• Identifying procedures for management, employees, and suppliers to follow so they better identify, prevent and mitigate the use of forced labor in our supply chain;
• Training Company employees and management, who have direct responsibility for supply chain management, on monitoring and mitigating risks related to the presence of slavery and human trafficking within the product supply chain; and
• Requiring suppliers to certify that they will not using forced or compulsory labor and will (i) ensure that overall terms of employment are voluntary; (ii) comply with minimum age requirements prescribed by applicable laws or contracts; (iii) compensate workers with wages and benefits that meet or exceed legally required minimums and overtime pay requirements; and (iv) abide by applicable law concerning the maximum hours of daily labor.

If we are made aware that a supplier is engaged in human trafficking or using slave labor, we will not continue to purchase goods or services from such supplier. Although neither we nor a third party currently evaluate our supply chains for risks associated with these practices, we are exploring the possibility of requiring direct suppliers to be responsible for monitoring the compliance of their own suppliers with our policy. We also plan to review our current supplier agreements, as well as the terms and conditions found in our standard purchase agreements, to determine ways to ensure our suppliers are complying with our policy against slavery and human trafficking. Further, while we do not currently conduct audits of our suppliers, we are considering the role of internal audits and self-reporting by suppliers as a method of compliance. Independent auditors or unannounced audits are not currently employed but will be considered if the circumstances require.