Supply Chain Transparency

Policy Against Slavery and Human Trafficking

Yokohama Tire Corporation ("Yokohama") is committed to a work environment free from human trafficking and slavery. 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. Accordingly, Yokohama employees and suppliers are expected to abide by these same principles. All Yokohama management and staff are responsible for following these policies. Over time, Yokohama will continue to develop and clarify these policies and supplementary procedures. Willful noncompliance with these policies and procedures may be subject to disciplinary action.

What is Human Trafficking? What is Slavery?

According to the United Nations, "human trafficking" is "the process by which a person is recruited, transported, transferred, harbored, or received through a use of force, coercion, or other means, for the purpose of exploiting them." The United Nations also defines "slavery" as "the status or condition of a person over whom any or all the powers attaching to the right of ownership are exercised," or "the status or condition of a person over whom control is exercised to the extent that the person is treated like property." This policy also covers forced labor (all work or service, not voluntarily performed, that is obtained from an individual under threat of force or penalty) and harmful child labor (the employment of children that is economically exploitative, or is likely to be hazardous to, or interfere with, the child's education, or to be harmful to the child's health, or physical, mental, spiritual, moral, or social development).

Policy Against Slavery and Human Trafficking

Yokohama is developing policies and procedures that support the disclosure requirements of the California Transparency in Supply Chains Act of 2010, Cal. Civ. Code § 1714.43. Such policies and procedures may include:

• Public disclosures of our policy against slavery and human trafficking, along with our activities implementing the same, on Yokohama's website;
• Procedures outlining what is expected from management, employees, and suppliers to better identify, prevent and mitigate the use of forced labor in our supply chain, including, but not limited to maintaining open lines of communication between these parties;
• A plan to initiate training for company employees and management who have direct responsibility for supply chain management focusing, among other things, on monitoring and mitigating risks related to the presence of slavery and human trafficking within the product supply chain;
• and Supporting compliance by suppliers with the laws regarding slavery and human trafficking in the country or countries in which those suppliers operate with respect to the products or materials they supply. Such compliance includes:
• Not using forced or compulsory labor;
• Ensuring that overall terms of employment are voluntary;
• Complying with minimum age requirements prescribed by applicable laws or contracts;
• Compensating workers with wages and benefits that meet or exceed legally required minimums and overtime pay requirements;
• and Abiding by applicable law concerning the maximum hours of daily labor.
• Yokohama may also require suppliers to certify to its compliance with the above requirements.

Yokohama will not continue to purchase goods or services from any supplier of which it is made aware to be engaging in human trafficking or using slave labor without proper cure or remedy of such practices. Yokohama is permitted to audit its suppliers' compliance with these policies. If the supplier is presenting a serious risk, the audit may be unannounced. Although Yokohama regularly monitors its suppliers for a variety of reasons, an audit is typically not performed to determine compliance with the prohibitions against slavery and human trafficking, nor are these audits typically conducted by third parties. Nevertheless, Yokohama will promptly and thoroughly investigate any claim or indication that a supplier is engaging in human trafficking or slave labor.

Procedures

Yokohama Tire Company fully supports the purpose and goals of the California Transparency in Supply Chains Act of 2010 and opposes any use of slavery or human trafficking in the manufacture and distribution of our products. We have adopted an initial company policy condemning the use of slavery and human trafficking. We are continuing to develop this policy to include processes that will help identify, prevent and mitigate the impact of forced labor in our supply chain and that will hold our employees and suppliers appropriately accountable for the policy's implementation. Moreover,

• We maintain open lines of communication with our suppliers, managers, employees, investors, customers, and other stakeholders.
• We are evaluating our 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. 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 are also considering how to properly provide training on our policy to our employees and managers on our policy and processes.
• Although 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.