3. SMBC Leasing and Finance, Inc.
SMBC Leasing and Finance, Inc., Corporate Structure
SMBC Leasing and Finance, Inc., is incorporated in the state of Delaware, USA, with a London Branch registered in England and Wales. SMBC Americas Holdings, Inc., a Delaware corporation (“SMBCAH”) directly owns 100% of the voting shares of SMBC Leasing and Finance, Inc.
SMBCAH is a wholly-owned subsidiary of Sumitomo Mitsui Banking Corporation, a Japanese banking institution (“SMBC”), and SMBC is in turn a wholly-owned subsidiary of Sumitomo Mitsui Financial Group, a financial services conglomerate that is also incorporated in Japan.
SMBC Leasing and Finance, Inc., Business
SMBC Leasing and Finance, Inc., purchased its UK based subsidiary, SMBC Leasing (UK) Ltd., from SMBC Leasing Company Limited (Japan) on June 22, 2006. SMBCLF and its subsidiaries are engaged in the leasing of personal or real property, or acting as agent, broker or adviser in leasing of such property, in net, full-payout leasing transactions and making, acquiring or servicing loans and other extensions of credit such as would be made by a commercial finance company of the kind permitted for bank holding companies under the US Bank Holding Company Act and Regulation Y of the United States Federal Reserve System.
Slavery and Human Trafficking Statement
Modern Slavery Act 2015 of the United Kingdom
The Modern Slavery Act 2015 (the “Act”) of the United Kingdom requires certain businesses to provide disclosure concerning their efforts to address the issues of Slavery and Human Trafficking in their supply chain. The disclosure is intended to provide customers the ability to make better, more informed choices about the products and services they buy and the companies they support, and has been prepared in accordance with the UK Home Office statutory guidance1 on complying with Section 54 of the Act.
This document comprises the Slavery and Human Trafficking Statement of SMBC Leasing and Finance, Inc. (“SMBCLF”), its London Branch and its UK subsidiaries (collectively, “SMBCLF-UK”) for the financial year ended 31 December 2020.
SMBCLF-UK's stance on Slavery and Human Trafficking
As part of SMFG, SMBCLF adheres to the group commitments to Corporate Social Responsibility (CSR), and the SMFG Statement on Human Rights, which reiterates the ethical responsibility to help protect and promote human rights.
SMBCLF-UK is committed to maintaining and improving systems and processes to mitigate the risk that it might be involved, wittingly or unwittingly, in the commission or facilitation of Slavery and Human Trafficking in any part of its operations, supply chain (including customers, contractors and suppliers), products, services and staff activities. SMBCLF-UK is committed to maintaining and improving systems and processes to mitigate the risk that it might be involved, wittingly or unwittingly, in the commission or facilitation of Slavery and Human Trafficking in any part of its operations, supply chain (including customers, contractors and suppliers), products, services and staff activities.
SMBCLF-UK also expects its staff, suppliers and business partners to adhere to the same high standards and to take reasonable steps to ensure that other third parties they do business with adhere to those standards as well.
SMBCLF-UK adheres to the Anti-Slavery and Human Trafficking Policy and Procedures of SMBC’s EMEA (Europe, the Middle East and Africa) Division. These policies and procedures provide appropriate and detailed guidance to SMBCLF-UK's staff on what constitutes an offence and the controls in place to mitigate the risk that SMBCLF-UK may be directly or indirectly involved in the commission or facilitation of Slavery and Human Trafficking.
SMBCLF-UK also adheres to SMBC EMEA Division’s Financial Crime governance framework, which includes an Antimoney Laundering/Combating of Terrorist Financing (AML/CTF) Policy, Anti-Bribery and Corruption (ABC) Policy, AntiFraud Policy, and Gifts and Entertainment (G&E) Policy. The Anti-Slavery and Human Trafficking Policy is aligned to, and is supported by, these policies.
The SMBC EMEA Division has enhanced its risk assessment of countries, industry sectors, goods and products, which have been reported to be involved in the potential commission or facilitation of slavery and human trafficking. Specifically, the assessment of goods and industry sectors has been updated in line with the United States Department of Labor – Bureau of International Labor Affairs (ILAB) list of goods produced by child labour or forced labour.
SMBCLF-UK is required to conduct appropriate checks in order to obtain reasonable assurance that customers, business partners, suppliers, and other third parties are not involved in the commission or facilitation of Slavery and Human Trafficking.
SMBCLF-UK requires specific anti-slavery due diligence to be undertaken on all its counterparties, and applies consistent due diligence measures for Slavery and Human Trafficking, whereby suppliers, contractors, customers and any other business partners are all subject to the same level of identification, verification, and risk evaluation. In addition, in the course of conducting due diligence processes, all customers, business partners, suppliers and other third parties are subject to adverse news screening, incorporating specific terms relevant to Slavery and Human Trafficking.
SMBCLF-UK expects its suppliers to undertake ethical business practices, particularly in, but not limited to, economic sectors where there are higher risks of Slavery and Human Trafficking. SMBCLF-UK takes appropriate steps to verify, evaluate and mitigate the risk that Slavery and Human Trafficking may occur in its supply chain. In particular, SMBCLFUK performs due diligence on suppliers and contractors at the start of a business relationship and subsequently on a periodic basis. This due diligence process includes, but is not limited to, an analysis of the activity carried out by the suppliers and contractors and a detailed review of publicly available information, in order to identify instances that may give SMBCLF-UK cause for concern.
SMBCLF expects its customers to undertake ethical business practices, particularly in, but not limited to, economic sectors where there are higher risks of Slavery and Human Trafficking. SMBCLF-UK takes appropriate steps to verify, evaluate and mitigate the risk that their products or services may be used by a customer for the commission or facilitation of Slavery and Human Trafficking.
As part of its on-boarding and periodic customer due diligence processes, SMBCLF-UK performs a series of checks on its customers, including, but not limited to, an analysis of the activity carried out by the customers and a detailed review of publicly available information, in order to identify instances that may give cause for concern.
In order to ensure proper understanding of the risks posed by Slavery and Human Trafficking in the context of SMBCLFUK’s supply chains and business, SMBCLF-UK's staff responsible for the above areas have received training on Slavery and Human Trafficking and the requirements of the Act.
All staff are encouraged to report any instances of suspected Slavery and Human Trafficking identified in any part of SMBCLF-UK’s business activities, either through their standard reporting lines, or through the whistleblowing programme of SMBC’s EMEA Division that is also available to SMBCLF-UK.
Slavery and Human Trafficking
As used in this Statement, the term “Slavery and Human Trafficking” refers to a variety of offences, including but not limited to:
- Slavery, servitude and forced or compulsory labour;
- Sexual exploitation, including all offences contemplated in the Part 1 of the UK Sexual Offences Act 2003;
- Removal and trafficking of organs outside the context of authorised health treatments;
- Securing services or other type of benefits by force, threats or deception; and
- Securing services or other type of benefits from children and vulnerable persons.
Questions, comments and requests regarding this Statement are welcomed and should be addressed. email@example.com
This Statement was approved by the Board of Directors of SMBCLF on September 14, 2021 and has been signed on behalf of the Board by Mr. Stephen Perry, President of SMBC Leasing and Finance, Inc.
Modern Slavery Statement in accordance with the Modern Slavery Act 2018, Commonwealth of Australia
This statement summaries the current approach to modern slavery of SMBC Leasing and Finance, Inc. (SMBC-LF) and outlines the actions that we have taken to mitigate the risk that human trafficking and modern slavery are not taking place in our business or our supply chains. It is also intended to assist customers to make better, more informed choices about the products and services they buy and the companies they support.
This statement has been prepared by SMBC-LF as the reporting entity in accordance with the UK Home Office statutory guidance 1 on complying with Section 54 of the 2015 Act and Modern Slavery Act 2018 (Commonwealth of Australia).
Both Acts require SMBC-LF to provide disclosure concerning its efforts to assess and address the risks that modern slavery practices may be occurring in its operations and supply chain of any entities that it owns or controls.
2. SMBC-LF’s structure, operations and supply chains
SMBC-LF’s company structure
SMBC-LF is an international leasing and finance company incorporated in the State of Delaware, USA.
Sumitomo Mitsui Financial Group, Inc.
SMBC-LF is a wholly-owned indirect subsidiary of Sumitomo Mitsui Financial Group, Inc. (SMFG) and is part of the SMFG group of companies (SMFG, together with its subsidiaries and affiliates are referred to as “SMBC Group”). SMFG is a publicly listed company. SMFG’s common shares are listed on the first section of the Tokyo Stock Exchange and the Nagoya Stock Exchange. SMFG’s American Depositary Receipts are also listed on the New York Stock Exchange.
SMBC Group is a global financial group that develops operations in a wide range of fields including banking, leasing, securities, credit cards and consumer finance. SMBC Group is comprised of four business units: the Retail Business Unit, the Wholesale Business Unit, the Global Banking Business Unit and the Global Markets Business Unit.
SMBC Group’s overseas network currently is comprised of offices in more than 40 countries and regions. As at 31 March 2022, SMBC Group had approximately 101,023 employees.
Further information on SMBC Group’s business can be found in SMFG's annual report and financial statements, which can be accessed at: https://www.smfg.co.jp/english/.
SMBC-LF specializes in originating, structuring, arranging and investing in structured assetbased, tax efficient and accounting driven financings in the US and worldwide.
SMBC-LF has offices in two (2) countries with approximately 20 employees. SMBC-LF has operations in Australia and the United States of America. As a subsidiary of Sumitomo Mitsui Banking Corporation (“SMBC”), SMBC-LF supports an extensive global network of SMBC group entities which SMBC either owns or controls. These group entities operate throughout these regions providing the financial services and credit related businesses to SMBC’s global network of customers. Further information on SMBC’s business, including a list of SMBC’s principal domestic subsidiaries, principal overseas subsidiaries and principal affiliates and a summary of the main businesses of these companies can be found here:
SMBC-LF in Australia
SMBC-LF established its presence in Australia in 2014 through its branch (ARBN 602 309 366) in Sydney, New South Wales.
SMBC-LF’s Australian operations are based in Sydney, New South Wales. SMBC-LF’s registered office in Australia is Level 40, The Chifley Tower, 2 Chifley Square, Sydney, New South Wales Australia.
In Australia, SMBC-LF provides financial advisory, lease financing, receivable purchases and asset backed debt financing for wholesale customers only. The Australian operations form part of the International Business Unit of SMBC Group.
Further information on SMBC’s global and Australian businesses can be accessed at: https://www.smbc.co.jp/global/; and https://www.smbc.co.jp/asia/australia/.
SMBC’s supply chains
SMBC’s business is primarily undertaken in an office environment with the majority of its suppliers providing goods and services in connection with office premises (such as stationery supplies, cleaning services and food and refreshments supplies), financial, technology and other professional services and corporate travel.
Given its geographic spread, SMBC’s supply chain is geographically diverse with suppliers from countries in which SMBC has operations.
SMBC’s suppliers range from small businesses to international organisations, operating across the developed and developing regions in which SMBC has operations.
Further, SMBC is connected with many thousands more organisations across the world via the supply chains of its first tier suppliers.
By way of example, the main categories of suppliers and service providers (by aggregate dollar value for the financial year ending 31 March 2022) for SMBC Sydney Branch relate to information technology equipment and software; rent; information services; market research; hospitality (including business travel); telecommunications; and professional advisers.
The arrangements SMBC Sydney Branch has with its suppliers are combination of long- term relationships with large multinational suppliers established and maintained as part of SMBC’s global operations and short-term relationships with smaller local suppliers. This list is broadly reflective of the categories of suppliers and service providers of SMBC globally and the entities which it owns or controls.
3. SMBC-LF and SMBC’s risks of modern slavery practices in operations and supply chains
SMBC-LF uses the technology, policies and procedures provided by SMBC to identify and capture risks associated with modern slavery.
SMBC conducts business internationally with operations spanning developed and developing countries and regions. Given the breadth of these operations, there is a potential risk that elements of the supply chain are engaging in modern slavery practices, particularly parts of the supply chain relating to the supply of goods and services. The risk is increased in relation to suppliers to SMBC’s operations in developing countries and regions.
SMBC’s supply chain includes a number of products that have been linked with modern slavery. For example, according to the Global Slavery Index 2018, the number 1 product category at risk of modern slavery imported into G20 countries (by US$ value) are laptops, computers and mobile phones. SMBC’s operations rely heavily on the use of laptops, computers and mobile phones. Using the Global Slavery Index 2018 as a source, SMBC has identified Information Technology services and software, manufacturing, agriculture, construction, mining, trade and service industries (such as hospitality and cleaning) as high risk sectors for modern slavery. SMBC operates in the banking and financial services industry and primarily within an office environment and therefore it does not operate in these sectors.
While SMBC aims to mitigate the risk that its suppliers are directly engaged in modern slavery, there is also a risk that suppliers have modern slavery risks in their own supply chains.
SMBC-LF outsources certain functions to SMBC and third party service providers. For example, SMBC-LF engages various third parties to provide services, such as information technology systems development and document archiving. There is a risk that such providers have modern slavery risks within their operations and supply chain, particularly given that most of these services are heavily reliant on IT hardware and software. These entities are assessed for their approach to managing modern slavery risk. SMBC continues its review of its modern slavery supply chain risk. It continues to consult with the group entities within its operational control. Given that such entities operate in the same financial services industry as SMBC, it believes that the modern slavery risks in its operations and supply chains is representative of the risks in the operations and supply chains of such group entities.
It is also acknowledged that modern slavery risks can also arise through the operations and actions of SMBC-LF’s customers. SMBC, therefore, may be linked to such risks, as a provider of financial services. Again, where these customers operate within jurisdictions or sectors with a high risk of modern slavery, this risk is heightened.
4. SMBC-LF and SMBC’s actions to assess and address risks of modern slavery practices
(1) SMBC’s commitment and policies in relation to slavery and human trafficking
SMBC is committed to maintaining and improving systems and processes to mitigate the risk that it might be involved, wittingly or unwittingly, in the commission or facilitation of Slavery and Human Trafficking in any part of its operations, customers and supply chain (including contractors and suppliers), products, services and staff activities.
As a signatory to the United Nations Global Compact, the SMBC Group is also committed to fulfilling the social responsibilities that are expected of it as a global financial group to create a society that is built on the utmost respect for human rights as directed by the "Universal Declaration of Human Rights," the "ILO Declaration on Fundamental Principles and Rights at Work," the "ISO 26000" guidelines on the social responsibilities of organisations, and the "Guiding Principles on Business and Human Rights" advocated by the UN Human Rights Council in 2011.
a. Initiatives for Sustainability
SMBC Group has positioned the sustainable development of society as a key issue and in October 2018, the establishment of its Corporate Sustainability Committee enables SMBC Group to better carry out the group’s Corporate Social Responsibility (CSR) and Environmental, Social and Governance (ESG) commitments.
In addition, SMBC Group has established the “SMBC Group environmental and Social Framework” in FY2021 in order to unify its internal policies on and approach to environmental and social issues.
This framework clarifies the Group’s approach to climate change, natural capital, respect for human rights, and social contribution based on the “SMBC Group Statement on Sustainability”, which states the Group’s basic stance toward realizing a sustainable society, The Group’s governance system for ESG risks is organized under this framework, including due diligence and policies related to each sector and business.
SMBC Group also formulated policies for specific businesses and sectors which are likely to have significant impacts on the environment and society. During FY2021, in the perspective of environment and respecting human rights, we decided to revise our policy for coal mining to not support newly planned and the expansion of thermal coal mining projects, as well as newly planned and the expansion of infrastructure developments that are dedicated to such projects
Further information on SMBC Group’s commitment to sustainability and policies for specific business and sectors can be found here:
b. SMBC Group’s statement on human rights
During FY2020, SMBC Group enhanced its Statement on Human Rights, which recognises the ethical responsibility of the SMBC Group to support and respect the protection of internationally proclaimed human rights and to prevent complicity on human rights violations. As noted in its statement, through dialogue and collaboration with stakeholders, SMBC Group aims to eliminate all forms of exploitative labor practices in its business and supply chains, including modern slavery, forced labor, human trafficking and child labor.
Further information on SMBC Group Policy Statement on Human Rights can be accessed at:
c. Principles of Action on Compliance and Risk
SMBC Group has established the “Principles of Action on Compliance and Risk”, which is a fundamental guidance from a compliance and risk perspective, on how SMBC group employees should act, in accordance with our Group Mission, Vision and Values.
The “Principles of Action on Compliance and Risk” require that SMBC Group employees respect human rights and embody these principles through its business, in order for SMBC group to realise the sustainable growth of its corporate values.
Further information on SMBC group’s Principles of Action on Compliance and Risk can be accessed at:
d. Sustainable Procurement Policy
SMBC Group published the “Sustainable Procurement Policy” on April 1st, 2022, in order to strengthen responsible procurement activities that carefully considers the environment and society throughout its supply chain.
This policy is based on the 10 principles of the United Nations Global Compact, the OECD Guidelines for multinational enterprises, the United Nations Guiding Principles on Business and Human Rights, and other international principles.
SMBC Group’s procurement activities are carried out in accordance with fair, impartial and transparent procedures based on free competition, which is in line with this policy and other relevant laws and regulations.
Further information on SMBC Group Sustainable Procurement Policy can be accessed at:
e. Anti-Slavery Policy
An Anti-Slavery Policy has been implemented within SMBC London Branch, which sets out the processes through which it seeks reasonable assurance that none of its customers, business partners, suppliers and other third parties are involved in the commission or facilitation of Slavery and/or Human Trafficking.
The Anti-Slavery Policy is supplemented by procedures and detailed guidance on what constitutes an offence and the controls in place to mitigate the risk that the branch may be directly or indirectly involved in the commission or facilitation of Slavery and/or Human Trafficking.
(2) SMBC’s actions in connection with its workplace environment, customer and supplier
SMBC is committed to prevent and remediate modern slavery risks by taking the following steps and actions.
SMBC-LF seeks to provide a workplace free from any type of violation of employees' human rights, including but not limited to, forced labour, harassment and discrimination without distinction of any kind such as race, gender, sexual orientation, gender identity, religion, creed, national origin, disability, family status and birth status. This is reflected in SMBC Group’s numerous public statements on its commitment to protecting human rights as well as its employee codes of conduct and policy and procedure manuals in operation across its global network.
SMBC Group has systems in place (grievance mechanisms) through which various stakeholders can raise human rights issues associated with its business. Customers can contact SMBC Group through the call center, telephone, and website. Employees can raise their concerns via dedicated internal whistle-blowing channels.
Members of staff are encouraged to report any instances of suspected Slavery and Human Trafficking identified in any part of SMBC’s business activities. The options for raising concerns and reporting are incorporated within SMBC’s whistleblowing program.
The credit policy of SMBC Group prohibits granting credit to certain businesses and customers, which includes those who exhibit unacceptable practices from the perspective of public order and morals.
There is a prohibition on the origination of loans for certain types of businesses where human rights abuses, such as child labour is, or may, be taking place or is likely to take place.
Furthermore, SMBC has been a signatory to the Equator Principles since 23 January 2006. The Equator Principles are a set of guidelines developed by private financial institutions for managing environmental and social risks related to financing large-scale development projects. The Equator Principles apply to project finance transactions, project-related corporate loans and bridge loans that are intended to be refinanced to project finance or corporate loans, regardless of the country or the sector.
The Equator Principles are based on the environmental and social policies and guidelines of International Finance Corporation, the private sector arm of the World Bank. These policies and guidelines cover a variety of issues such as the environmental and social impact assessment process, pollution prevention, consideration of local communities and natural resources.
In accordance with the Equator Principles, SMBC has established internal environmental and social guidelines and procedures, and conducts environmental and social risk assessments, including in respect of potential adverse human rights impacts.
SMBC Group commissioned an independent external party (Ernst & Young ShinNihon LLC) to review a number of transactions for the year ended 31 December 2019 regarding their compliance with the Equator Principles, including 64 Project Finance transactions closed in 2019; 12 Project Related Corporate Loans closed in 2019; and 24 Finance Advisory Transactions mandated in 2019.
An Independent Assurance Report was issued by Ernst & Young ShinNihon LLC on 1 June 2020, wherein no adverse finding or non-compliance had been noted.
Furthermore, in accordance with the SMBC AML/CFT Global Procedures, SMBC-LF conducts due diligence on its customers at both the on-boarding stage and at regular periods thereafter, as part of its anti-money laundering compliance responsibilities.
In SMBC-LF the due diligence includes compliance specific database searches on customers in relation to adverse news, which would identify news in connection with sanctions and human rights violations. This also includes ongoing screening in respect of customers, customer associated parties and trade finance transactions for connections to jurisdictions with human rights issues.
Furthermore, SMBC established human rights working group in FY2021, which includes various corporate departments, to discuss and introduce efficient measures to prevent human rights abuse. As a result, SMBC is planning to introduce a new set of measures concerning human rights due diligence on clients and projects that SMBC provides loans to, in order to identify and assess the risks concerning modern slavery. In addition, we also introduced enhanced due diligence for clients operating in a sector that is considered high risk from a modern slavery or human trafficking perspective.
c. Supply Chain
SMBC takes appropriate steps to verify, evaluate and mitigate the risk that Slavery and Human Trafficking may occur in its supply chain.
In Japan, SMBC has established Outsourcing Management Procedures, which require every office to perform due diligence on third parties in relation to Slavery and Human Trafficking by reviewing publicly available information.
In FY2020, the SMBC Group Outsourcing Due Diligence Program was enhanced to ensure an assessment and monitoring of all vendors/service providers (regardless of whether the service is considered to be outsourcing) is undertaken at least annually. The three areas of focus include the Japanese Anti-Social Forces Screening, Anti-Bribery and Corruption Due Diligence and Modern Slavery Due Diligence.
SMBC has also established Outsourcing Management Procedures for Overseas Offices, which stipulates that overseas offices should conduct appropriate due diligence in relation to Slavery and Human Trafficking. This due diligence process includes reviewing publicly available information such as the third party’s or its parent company’s website in respect of its policies or positions on the protection of human rights, as well as internet searches to determine whether there is any adverse news in respect of human rights violations. Per SMBC Group policy, contracting with a third party is prohibited if the third party is engaged / involved in human rights violations. Results of the assessments for all SMBC offices are consolidated and reported as part of the SMBC Risk Management program. SMBC Australia engaged a third party global compliance and due diligence company that specialises in third party due diligence and management. For the next financial year, the top 20 vendors by annual aggregate expenses engaged by SMBC Australia will be requested to answer a series of questions through an online platform that has been tailored for SMBC Australia, which will assist SMBC Australia to assess the modern slavery risk within its supply chain and enable it to focus its efforts on any high-risk suppliers. SMBC London requires specific anti-slavery due diligence to be undertaken on all its counterparties, and applies consistent due diligence measures for Slavery and Human Trafficking, whereby suppliers, contractors, customers and any other business partners are all subject to the same level of identification, verification, and risk evaluation.
As part of the on-boarding and periodic due diligence processes in SMBC London Branch, all counterparties are assessed to determine if they fall within the scope of the Act, and, if so, a copy of their Anti-Slavery Statement is sought and retained. By way of best practice, for those counterparties who are not in scope of the Act, SMBC London Branch will seek to obtain an equivalent policy or document relating to CSR, ESG or Human Rights.
5. SMBC’s methods to assess effectiveness of actions
Modern slavery has been introduced in the SMBC Group global compliance risk assessment framework.
Consistent with the SMBC Group global compliance risk assessment program, effectiveness is determined on an assessment as to:
- appropriate design of relevant policies and procedures to ensure compliance and risk management;
- how well the control processes have operated, including timeliness and comprehensiveness;
- the extent of employee training that has been conducted;
- the outcomes from monitoring and validation procedures; and
- the timeliness of remedial action taken for any issues arising.
Enhancements may be made as considered necessary as a result of these assessments.
6. SMBC’s consultation process with its subsidiaries and other controlled entities
The global compliance risk assessment framework referred to above is a channel for SMBC offices to provide feedback to Head Office through the annual reporting of risk assessment and implementation of control practices to assist in mitigating risks. As well, the enhanced Vendor and Outsourcing review management program provides an additional source of information for SMBC to assess the modern slavery risks associated with its suppliers and outsourced activities.
In order to ensure proper understanding of the risks posed by Slavery and Human Trafficking in the context of SMBC’s supply chains and business, SMBC provides training to staff on Slavery and Human Trafficking and the requirements of the Act.
SMBC has provided specific training in relation to modern slavery, incorporating relevant resources and due diligence requirements, as a part of compliance training. At the end of FY2021, nearly 21,000 employees which accounts for most of SMBC employees in Japan, had completed the training.
SMBC Australia is also including modern slavery and human trafficking risks as well as due diligence measures undertaken in its compliance training program.Furthermore, during FY2021, SMBC planned to hold a study session for executives by inviting human rights experts to enhance their understanding of modern slavery, and the study session was conducted in May 2022. SMBC will also continue to provide the training in relation to human rights on regular basis for our employees in order to promote awareness of human rights.
This Statement was approved by the SMBC-LF Board of Directors on 20 December 2022 and has been signed on behalf of the Board by Mr. Stephen R. Perry, President of SMBC-LF.