Internal Control System

The Company's internal control system is established to thoroughly ensure the effectiveness and efficiency of operations, the reliability of financial reporting, compliance with relevant laws and regulations, the preservation of assets, and risk management. The basic policy on the development of the internal control system has been resolved by the Board of Directors and is reviewed in a timely and appropriate manner, the contents of which are as follows. The operational results based on this policy in FY2025 are described in the matters subject to electronic provision measures (non-deliverable documents) for the 98th Ordinary General Meeting of Shareholders. The names of organizations and internal regulations are as of the submission date.
The Company has established the systems necessary to ensure that the execution of duties by the Company's Board of Directors complies with laws, regulations, and the Articles of Incorporation, as well as the systems necessary to ensure the appropriateness of the Company's operations, as set forth below. The Company continuously reviews and develops this policy and these systems in a timely and appropriate manner, and strives to maintain and improve the soundness and transparency of management and the efficiency and agility of business execution through thorough implementation and monitoring of operations.

1. Systems to ensure that the execution of duties by Directors and employees complies with laws, regulations, and the Articles of Incorporation

(1)

Directors and employees shall act in accordance with the "Fuji Oil Group Constitution," which sets forth in writing the Group's mission, vision, the values to be held in taking action, and action principles.

(2)

The Company shall establish the "Nomination and Compensation Advisory Committee," the majority of which consists of Independent Outside Directors, as a discretionary advisory body to the Board of Directors, in order to ensure transparency in the processes of officer appointment and the determination of officer remuneration.

(3)

If there is any act in the Company that violates the action principles of the "Fuji Oil Group Management Philosophy," laws and regulations, or other compliance matters, and correction through the organizational hierarchy does not function, officers and employees (collectively referring to those engaged in the operations of the Company or the Fuji Oil Group; the same applies hereinafter) shall be able to report such matters through the "Internal Whistleblowing System." In such cases, the Company ensures that whistleblowers do not suffer any disadvantage as a result of reporting. In addition, the Company establishes the "Internal Whistleblowing Regulations" and ensures operational effectiveness by having an external attorney serve as the "reporting desk." For overseas Group companies, a multilingual reporting desk (name: Compliance Helpline) is established to strengthen the compliance system across the entire Fuji Oil Group.

(4)

The Company, as a basic policy, does not have any contact with illegal forces and maintains a resolute stance against antisocial forces that pose a threat to the order and safety of civil society.

(5)

The Company establishes the Internal Audit Department as its internal audit division. It conducts internal audits regarding the status of compliance with laws and regulations, the Articles of Incorporation, and internal regulations, and reports the results to the Audit and Supervisory Committee and the Board of Directors.

2. Structure for the retention and management of information related to the execution of duties by Directors

The Company appropriately retains and manages documents (including electromagnetic records) prescribed by laws and regulations and other documents containing important information related to the execution of duties, in accordance with the "Document Management Regulations," "Information Management Regulations," and other internal regulations.

3. Regulations and other structures for the management of the risk of loss

(1)

The Company establishes the "Risk Management Regulations" and, through the Risk Management Committees set up at each Group company, comprehensively identifies company-wide risks at the Company's Management Committee Meeting, specifies material risks, and reports them to the Board of Directors, which serves as the monitoring body. At the Management Committee Meeting, positioned as the company-wide risk management body, an officer in charge of each risk is designated to plan, implement, monitor the progress of, and evaluate and improve countermeasures. The matters examined and addressed are reported to the Board of Directors at least once a year, and the Board of Directors monitors them.

(2)

For crisis response, the Company establishes the "Regulations on Crisis Response" and, depending on the severity of the impact on the entire Group, sets up an Emergency Response Headquarters headed by the president at the Company or each Group company to respond promptly. In addition, the Company develops a "Crisis Management Public Relations Manual" to appropriately carry out initial responses in the disclosure of information when a crisis occurs as the Fuji Oil Group.

4. Structure for ensuring that the execution of duties by Directors is performed efficiently

(1)

To accelerate decision-making, the Company develops internal regulations concerning the segregation of duties and authority, clarifies authority and responsibility, and, for important matters, contributes to the decision-making of the President and Representative Director and the Board of Directors based on deliberations at the Management Committee Meeting and other bodies whose main members are the President and Representative Director, business-executing Directors, and Executive Officers.

(2)

The Company establishes the Rules of the Board of Directors and, at the Board of Directors meetings held in principle once a month, makes decisions on important management matters and monitors the status of the execution of duties.

(3)

The Company establishes a medium-term management plan to clarify the goals to be achieved by the Company, and also clarifies the performance targets of business-executing Directors and Executive Officers.

(4)

We have established a management accounting system to ensure our ability to accurately ascertain the status of management performance in a timely manner. Through the practical application of this system, we have established a structure that enables speedy response to change.

5. Structure for ensuring appropriate operations at the corporate group comprising the company and its subsidiaries

(1)

We created the Fuji Management Regulations to outline the governance of Group companies, and to specify the divisions and persons responsible for Group company management. We require that all Group companies receive our approval for and report on the important matters outlined in our Decision-Making Authority Standards Table Regulations and Decision-Making Operation Regulations.

(2)

We maintain responsibility and authority over the management of Group companies. In addition to providing advice and guidance to ensure the appropriate application of the Fuji Oil Group Management Philosophy and any other Fuji Oil Group policies and regulations, we also manage overall Group risks and compliance by creating appropriate and necessary risk management structures and compliance structures based on company scope and organizational structure.

(3)

The Audit and Supervisory Committee cooperate with and direct the Internal Audit Department to conduct and audit the appropriateness of Group companies. When corrective action is necessary, the Internal Audit Department provides advice and/or warnings and submits reports on audit results to the Audit and Supervisory Committee and the Board of Directors.

(4)

Through the Fuji Management Regulations and other relevant regulations, we outline standards concerning Group division of labor, our command structure, authority and decision-making, and other standards related to our organization. We also ensure that subsidiaries establish equivalent structures.

(5)

The Company defines the roles and responsibilities relating to the tax business of the entire Group in the Tax Regulations. We build a structure to promote compliance with tax laws, ordinances and regulations, to manage tax risks and to optimize the amount of tax in each company in the Group.

6. Matters concerning Directors and employees assisting with the work of Audit and Supervisory Committee, Matters related to the independence of such employees from Directors other than Audit and Supervisory Committee Members and matters related to ensuring the effectiveness of instructions given to such employees

(1)

As necessary, the Audit and Supervisory Committee may designate employees to assist with their work. While, from the perspective of work, objectivity and efficiency, it is preferable to assign dedicated staff to assist the work of the Audit and Supervisory Committee, in some cases these roles are fulfilled by employees with responsibilities in other divisions. In these cases, competency and personnel evaluations for employees assigned as assistants is conducted with respect of opinions of the Audit and Supervisory Committee, and work assignment transfers for said employees are subject to the consent of the Audit and Supervisory Committee.

(2)

The Audit and Supervisory Committee exchanges opinions with President and Representative Director regarding the enhancement of the assistants, their independence from Directors (excluding Directors who also serve as Audit and Supervisory Committee Members) and ensuring the effectiveness of the Audit and Supervisory Committee's instructions to the assistants.

7. Structure for reporting to the Audit and Supervisory Committee

(1)

Directors who also serve as Audit and Supervisory Committee Members may attend Management Committee Meeting and other important meetings to gather information from directors, etc. concerning the status of operations and browse relevant documents.

(2)

Directors (excluding Directors who also serve as Audit and Supervisory Committee Members) shall provide timely reports to an Audit and Supervisory Committee on the following matters.

• 1. Events significantly damaging to or with the potential to significantly damage the company’s credit
• 2. Events significantly impacting or with the potential to significantly impact company performance in a negative way
• 3. Violations of law, the Articles of Incorporation, or the Fuji Oil Group Management Philosophy that have a major impact of the potential to have a major impact.
• 4. Matters equivalent to the above.

(3)

Directors (excluding Directors who also serve as Audit and Supervisory Committee Members) and employees shall, when requested by the Audit and Supervisory Committee, submit timely and accurate reports.

(4)

Group directors and employees shall, when requested by the Audit and Supervisory Committee, submit timely and accurate reports concerning their execution of duties.

(5)

The Company prohibits any unfair treatment of Group directors and employees for having submitted reports to the Audit and Supervisory Committee and a Group Audit & Supervisory Board Members, and we ensure awareness of this policy among Group directors and employees.

(6)

Details of matters reported to the Whistleblowing Desk (Japan) and the Compliance Hotline (overseas) are reported, either directly or indirectly, to Directors who also serve as Audit and Supervisory Committee Members.

8. Other structures for ensuring the effective implementation of audits by Audit and Supervisory Committee

(1)

The Audit and Supervisory Committee may browse major reports and other important documents related to business execution and, as necessary, may request explanations from directors and employees.

(2)

The Audit and Supervisory Committee regular engage in the exchange of opinions with President and Representative Director through Directors who also serve as Audit and Supervisory Committee Members and also cooperate with the Internal Audit Department and the accounting auditor to promote appropriate communication and effective audit work.

(3)

The Audit and Supervisory Committee may, at its own discretion, hire external experts when necessary for forming an independent opinion.

(4)

When Directors who also serve as Audit and Supervisory Committee Members requests an advance, etc. for expenses outlined in Companies Act Article 388 in relation to the execution of their duties, following deliberations by relevant departments, excluding when said expenses or liabilities are deemed unnecessary to the implementation of duties by Directors who also serve as Audit and Supervisory Committee Members , the Company will immediately handle said expenses or liabilities.

9. Structure for ensuring appropriateness in financial reporting

To ensure the appropriateness of financial reporting and to promote the submission of effective and appropriate governance reports as outlined in the Financial Instruments and Exchange Act, we constantly evaluate and implement improvements to ensure our internal controls system functions appropriately.