Japan Pulp & Paper Group Anti-corruption Policy

The Japan Pulp & Paper Group (the “group”) will strive to prevent bribery of public and government officials, inappropriate demands of business partners, and other acts of corruption.

1. Prohibition of Acts of Corruption

We will maintain transparency at all times with regard to public and government officials, and will not offer bribes or grant favors in any form.
We will always maintain fair and equal relationships with all our business partners, and will not give or receive gifts, entertainment, or other economic benefits that go beyond the scope of normal social courtesies.

2. Compliance with Relevant Laws and Regulations in All Countries

We will abide by all laws and regulations, guidelines, and other social norms relating to the prevention of bribery in all countries and regions in which we do business, as well as internal regulations.

3. Obligation to Keep Records

Whenever we give money or other benefits to a third party in the course of executing our business, we will make an accurate and complete record in accounting books, and will keep related documents that may serve as evidence.

4. Education and Training

To prevent corruption, and to ensure the legal compliance of our business operations, we will ensure that all executives and employees are fully aware of this policy, and will provide regular education and training to this end.

5. Establishment of a Whistle-blowing System

We will establish a system for receiving reports or whistle-blowing from executives and employees regarding actual or potential infringements of any laws or regulations related to the prevention of corruption, and will operate the system appropriately so that executives and employees who report or whistle-blow will not be disadvantaged.

6. Disciplinary Actions

Any executive or and employee found to be in violation of this policy will be subject to disciplinary actions in accordance with internal regulations.

Established February 8, 2022

Akihiko Watanabe, President
Japan Pulp & Paper Co., Ltd

Effective April 1, 2022