1. Introduction

The Denka Group has established the Denka Group Corporate Ethics Policy and the Denka Group Whistleblower 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 whistleblower system called the Denka Group Helpline.

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.

4. Response after Whistleblowing

After receiving a report, the hotline will notify the Denka Company Limited Ethics Committee Secretariat (Head of audit committee and Legal Department) of the details of the report.
The Ethics Committee Secretariat will sort and verify the contents of the report, and if it is deemed necessary to investigate, it will assemble an investigation team to investigate, with the protection of the whistleblower as its top priority, and if a problem is found, the company will take corrective measures. (If the perpetrator is a person related to a business related to the supply chain, we will consider necessary and possible responses, such as requesting that the business related to the supply chain take corrective measures.)

Whistleblowers will, in principle, receive feedback through the whistleblowing hotline regarding the need for investigation (within 20 days of receiving the whistleblowing report), investigation results, and corrective actions. However, if the whistleblower is anonymous and the whistleblower's contact information is unknown, it may not be possible to confirm the whistleblowing report, conduct subsequent investigations, or provide feedback on the results even if the report is made to the whistleblowing hotline.

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 the content of whistleblowing. Furthermore, Denka Group companies ensure that internal parties, including secretariats of ethics committees, investigation teams, investigation collaborators, and compliance personnel, receiving information from whistleblowing contact points uphold confidentiality obligations, including ensuring the anonymity of whistleblowers. Denka Group also strictly prohibits its officers and employees from seeking whistleblowers or investigation collaborators, treating them unfavorably, or engaging in retaliatory acts.

Number of whistleblowing cases

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