1. Introduction

The Denka Group has established the Denka Group Corporate Ethics Policy and the Denka Group Whistleblowing Policy to ensure compliance management across the Group and to facilitate the early detection and correction of compliance issues. Based on these policies, we have also established and are operating a Group-wide whistleblowing system called the Denka Group Helpline.
This whistleblowing system can be used by Denka Group officers and employees, business partners including suppliers, and other stakeholders.
Reports can be made regarding violations of laws and regulations, human rights infringements, violations of internal rules, or incidents that may be connected to these matters.
When making reports, the anonymity of the whistleblower and confidentiality of the content will be ensured, and whistleblowers will be protected so that no disadvantages will occur due to the reports.
For details, please refer to the following sections.

2. Intended Users and Content

The persons eligible to use the Denka Group Help Line and the contents that can be reported are as follows.

• ※1Refers to individuals engaged in business based on contracts such as subcontracting agreements with Denka Group companies.
• ※2Persons related to businesses involved in the supply chain of Denka Group companies (including sources of raw materials, outsourced service providers, and subcontractors and sub-subcontractors).
• ※3Examples include, but are not limited to, discrimination in the workplace, infringement of honor or privacy, and excessive working hours.
• ※4Only those directly related to the Denka Group companies' businesses, products, or services.

3. How to Use

According to the classification of intended users, you can report to the following internal and external contacts via the designated methods such as e-mail.
(Reports that are intended to defame others, provide intentional false information, or serve personal interests will not be accepted.)

Information to be provided to the whistleblowing hotline

When making a report, please provide the following information.

• Name of whistleblower (if anonymous, please state), affiliation, relationship with Denka Group companies
• Details of the misconduct
  (Please provide details as much as possible regarding “when,” “where,” “who,” “what,” “how,” and “why.”)
• How the whistleblower came to know of the above misconduct
• Presence of evidence records regarding the above misconduct
• Whether or not to be contacted in the future and contact information

4. Response after Whistleblowing

After receiving a report, the reporting hotline will notify the Denka Co., Ltd. Ethics Committee Secretariat (Director of audit committee and Legal Department) of its contents.
The Ethics Committee Secretariat will organize and verify the contents of the report, and if an investigation is deemed necessary, it will assemble an investigation team with the protection of the whistleblower as its top priority. If a problem is found, the company will take necessary corrective measures and preventative measures to avoid recurrence.
Regarding the incident in question, the Chief Compliance Officer (CCO) will notify all officers and employees of the entire group through each executive officer of Denka Co., Ltd., and will ensure that measures to prevent recurrence are thoroughly understood.
(If the perpetrator is a person involved with a supply chain, we will consider necessary and feasible measures, such as requesting that the supply chain company take corrective action.)

Whistleblowers will, in principle, receive feedback through the whistleblowing hotline regarding the necessity of investigation (within 20 days of receiving the whistleblowing report), investigation results, and corrective actions. However, if the whistleblower is anonymous and does not have a contact address, it may not be possible to confirm the whistleblowing report, conduct further investigation, or provide feedback on the results.

The handling of personal information (information that can identify individuals such as name, address, and email address) provided through the whistleblowing system will be used only to the extent necessary for confirming whistleblowing contents, conducting investigations, and contacting whistleblowers, and will be managed in accordance with the Denka Group Personal Information Protection Basic Policy.

5. Protecting Whistleblowers

The whistleblowing contact points maintain strict confidentiality regarding the names of whistleblowers and whistleblowing contents. Furthermore, Denka Group companies ensure that internal parties such as the secretariat of the Ethics Committee, investigation teams, investigation collaborators, and compliance personnel receive information from whistleblowing contact points, maintain confidentiality including ensuring the anonymity of whistleblowers, and strictly prohibit Denka Group officers and employees from searching for whistleblowers or investigation collaborators, treating them unfavorably, or taking retaliatory actions.
The secretariat of the Ethics Committee raises awareness of these points in internal compliance training, and aims to maintain trust in and promote the use of the whistleblowing system. The "Denka Group Internal Whistleblowing Policy" stipulates that strict measures including disciplinary action against violators will be taken in the event of violations of these obligations.

Number of whistleblowing cases

• ※1Includes items that were not recognized as fraudulent acts
• ※2Head office only
• ※3Only 8 major production sites in Japan