Faqs - EthicsPoint

Sojitz Ethics HotlineFrequently Asked QuestionsQ. Why does Sojitz have an ethics hotline?• We want to make sure there are multiple avenues for employees to report their concerns without fear ofretaliation. The Sojitz Ethics Hotline is a reporting tool designed to protect the anonymity andconfidentiality of those who use the system, to the extent permitted by law.• By creating open channels of communication, we can promote a positive work environment andmaximize productivity.• An effective reporting system can be our most useful tool in reducing losses due to fraud and/or abuse.Q. Who operates the Sojitz Ethics Hotline?The Sojitz Ethics Hotline is operated by an external organization called EthicsPoint, Inc. EthicsPointprovides a confidential and, if permitted by law and so desired, anonymous reporting tool. EthicsPointcollects information from the employee making a report on the website or by telephone and then passes thereport to Sojitz for follow-up and investigation. You can find out more about EthicsPoint atwww.ethicspoint.com.Q. May I report using either the internet or the telephone?Yes. By giving you choices, the Sojitz Ethics Hotline helps ensure that employees can file a report in themanner most comfortable or convenient to them.You can file a Sojitz Ethics Hotline report from any computer that can access the internet. You can file fromhome. Many public locations, including the public library, have internet computers.If you don’t have access or are uncomfortable using a computer to make a report, you can call your localSojitz Ethics Hotline toll-free number. The Sojitz telephone hotline is operated by EthicsPoint hotlinespecialists.You can make your report on either the website or by telephone in your native language. The Sojitz EthicsHotline website and toll-free hotline number are available 24 hours a day, 7 days a week, 365 days a year.Q. Does management really want me to report?We certainly do. In fact, we need you to report. You know what is going on in your Company - both goodand bad. You may have initial knowledge of an activity that may be cause for concern. Your reporting canminimize the potential negative impact on the Company and its people. Also, offering positive input mayhelp identify issues that can improve corporate culture and performance.Q. Why should I report what I know? What’s in it for me?We all have the right to work in a positive environment and with that right comes the responsibility of actingin an ethical manner and letting the appropriate people know if someone is not acting appropriately. Byworking together, we can maintain a healthy and productive environment. Corporate misconduct canthreaten the livelihood of an entire company.Q. What type of situations should I report? Do I need proof of wrongdoing before making a report?EthicsPoint is a communications tool providing an avenue for you to voice your suggestions and concernsand report conduct that may be unethical, illegal, in violation of professional standards, or otherwiseinconsistent with our Code of Conduct and Ethics.We encourage you to report any legitimate, good-faith concerns, even if you do not have proof of any wrongdoing.However, anyone who makes an intentional false allegation will be subject to disciplinary action, upto and including termination of employment.Q. I am not sure if what I have observed or heard is a violation of Company policy, or involves unethicalconduct, but it just does not look right to me. What should I do?File a report. EthicsPoint can help you prepare and file your report so it can be properly understood. We'drather you report a situation that turns out to be harmless than let possible unethical behavior go uncheckedbecause you weren't sure.Page 1 of 3

Sojitz Ethics HotlineFrequently Asked QuestionsQ. How does the Sojitz Ethics Hotline work? Where do these reports go? Who can access them?If you make a report via the Sojitz Ethics Hotline website, the site will prompt you to provide theinformation that is required to investigate a concern. You will have the option to navigate the site in severallanguages, and may make your report in your native language.If you contact the Sojitz Ethics Hotline by telephone, your call will be answered in English by anEthicsPoint hotline specialist. Depending on the language in which you wish to conduct the conversation,the call center specialist will either continue with the call, transfer it to a colleague who is able to speak yourlanguage, or ask an interpreter to join the conversation. The Sojitz Ethics Hotline supports most languages.On both the website and through the toll-free number, you will be given the option to either remainanonymous, if permitted by law, or to provide your name and contact details.Reports to the Sojitz Ethics Hotline are entered directly on the EthicsPoint secure server to prevent anypossible breach in security. EthicsPoint makes these reports available only to specific individuals within theCompany who are charged with evaluating the type of violation and location of the incident. Each of thesereport recipients has had training in keeping these reports in the utmost confidence.Q. What if my boss or other managers are involved in a violation? Won’t they get the report and start acover-up?The Sojitz Ethics Hotline system and report distribution are designed so that implicated parties are notnotified, unless required by law, or granted access to reports in which they have been named.Q. What if I remember something important about the incident after I filed the report? Or what if theCompany has questions for me concerning my report?When you file a report at the Sojitz Ethics Hotline website or through the toll-free hotline number, youreceive a unique report key and are asked to choose a password. You can return to the Sojitz Ethics Hotlineagain either by internet or telephone and access the original report to provide additional information. Westrongly suggest that you return to the Sojitz Ethics Hotline within ten days for a status report and to answerCompany questions.Depending on the complexity of the matter, when you return to the Sojitz Ethics Hotline you may be advisedthat the report is still being considered; that an investigation has been completed and whether or not actionis being taken; or you may be asked for more details about the report in order for the Company toinvestigate the matter further. However, for confidentiality reasons, you will not necessarily be told thespecifics of how a particular matter is being or has been resolved.Q. Are these follow-ups on reports as secure as the first report?All Sojitz Ethics Hotline correspondences are held in the same strict confidence as the initial report,continuing under the umbrella of anonymity, if permitted by law.Q. It is my understanding that any report I send from a computer generates a server log that shows everywebsite with which my PC connects. Won’t this log identify me as a report originator?EthicsPoint does not generate or maintain any internal connection logs with IP addresses, so no informationlinking your PC to EthicsPoint is available.Q. If I call the Sojitz Ethics Hotline, will my call be recorded?No. However, in order to create a report, the EthicsPoint hotline specialist will take notes of your call.Q. Is it possible that my call to the Sojitz Ethics Hotline can be traced back to me by using caller ID?No. Caller identification is disabled for all incoming calls.Page 2 of 3

Sojitz Ethics HotlineFrequently Asked QuestionsQ. I am concerned that the information I provide EthicsPoint will ultimately reveal my identity. How can youassure me that this will not happen?The EthicsPoint system is designed to protect your anonymity, and you are only asked to provide your nameand contact details if required by law. However, you as a reporting party need to ensure that the body of thereport does not reveal your identity by accident, for example, “From my cube next to Jan Smith…” or “In my33 years…”Q. What if I want to be identified with my report? If I identify myself, will my identity be kept confidential?You do not have to identify yourself when making a report on the Sojitz Ethics Hotline website or calling thetoll-free hotline number, if permitted by law. During the call or in a section of the website report, ifappropriate, you will be asked whether or not you wish to remain anonymous. You will be given the optionto have your identity and contact information made available to Sojitz without restriction; have your identityand contact information made available only to Sojitz personnel who are responsible for investigating ethicsmatters and who are obligated to keep such information confidential; or you can opt to remain anonymous, ifpermitted by law.However, you should note that it is not possible to guarantee absolute confidentiality in all circumstances.Disclosure to others inside or outside Sojitz may be required by law in certain circumstances, for instance, inthe case of a report of money laundering. In addition, it is possible that someone could guess your identityfrom the circumstances in your report. You should not let these possibilities discourage you from reporting aconcern.Q. What happens if somebody that I named in my report finds out that I made the report?It is Sojitz’s policy to encourage employees to report concerns about unethical or illegal behavior or activitiesthat are inconsistent with our Code of Conduct and Ethics, and to protect employees who raise suchconcerns from retaliation. The Company will take all reasonable precautions to protect your anonymity,consistent with law and Company policies.Retaliation is a serious violation of our Code of Conduct and Ethics and any retaliation by a Sojitz employeeis subject to disciplinary action, up to an including termination of employment.Q. Who should I contact if I have additional questions about the Sojitz Ethics Hotline?You may contact your manager, your local human resources personnel, or your regional Legal and/orCompliance Department representatives.Page 3 of 3