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Kajima Group Global Tax Compliance Policy

Kajima Corporation (hereinafter, the "Company") and its group companies (hereinafter collectively, the "Group") "strives to continually advance its business operations and contribute to society" under its Corporate Philosophy. Its objective is to earn the trust and regard of all stakeholders, including stockholders, customers, business partners, local communities and employees. The Kajima Group Code of Conduct provides that the Group should comply with all laws and regulations, including foreign and international rules, as well as their underlying spirit. Accordingly, the Group files appropriate tax returns in line with the relevant laws and regulations.

In conformance with these principles, the Group hereby sets forth its tax compliance policy which outlines those matters to be adhered to and abided by in accordance with applicable tax laws and regulations in the countries and regions where the Group operates its business.

Under the Kajima Group Global Tax Compliance Policy, the Group will continue to strive for transparent and appropriate tax payment by ensuring that each and every executive and employee is fully aware of his/her social responsibility, maintaining high ethical standards and prudence, and faithfully performs accounting and tax filing in strict accordance with relevant laws and regulations as well as applicable inhouse rules.

1. Tax governance

The General Manager of Treasury Division, fully authorized by the President of the Company, is held responsible for the tax governance of the Group.

Practical handling of tax matters is conducted by the relevant department of each group company. At the Company, this is delegated to Accounting Department of Treasury Division. The General Manager of Accounting Department oversees important tax matters in the Group, and reports to the General Manager of Treasury Division. Information is shared within the Group as necessary. The Group also retains external experts such as tax accounting and law firms as appropriate, seeking advice and practical support on the application and interpretation of tax related laws and regulations as well as information on the exemptions and benefits available in the tax law, thereby appropriately mitigating the tax risks in conformance with the Group's basic policies and guidelines, such as the Code of Conduct.

2. Complying with laws and regulations and assuring transparency

As a member of the societies of the countries and regions where the Group operates its business, the Group strives to fulfill its corporate responsibilities and obligations, and execute transparent and appropriate tax payment in compliance with the provisions of tax related laws and regulations as well as OECD Guidelines including the "Action Plan on Base Erosion and Profit Shifting" (BEPS).

3. Tax havens

The Group does not use tax havens for tax avoidance purposes.

In the case that any of the countries or regions where the Group operates its businesses is formally classified as a tax haven by reduction of effective tax rate or revision of tax system, the Group will execute appropriate tax filing and tax payment in compliance with the laws and regulations of Japan as well as those of each country or region.

4. Transfer pricing

Concerning cross-border transactions among the Group companies, the Group clearly defines the functions to be fulfilled and risks to be borne by each party, as well as its business positions within the Group, and operates business transactions at arm's length prices in line with the OECD Transfer Pricing Guidelines and the Japanese transfer pricing taxation system.

5. Good faith and positive relationships with tax authorities

The Group executes timely and proper tax filing with and tax payment to the relevant tax authorities of each country or region. When the Group receives an inquiry from a tax authority, it provides information in an appropriate and cooperative manner, and offer explanations in good faith, based on facts. In all matters, the Group strives to maintain a positive relationship with tax authorities.

If any discrepancies of opinion arise between the Group and the tax authorities, the Group actively provides them with sufficient explanations and strives to resolve the issue.

6. Tax payment amounts by region for the fiscal year ended March 31,2020

(Unit: Million yen)

Japan North America Europe Asia Oceania Other areas Total
36,419 2,383 193 3,789 45 - 42,830

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