Basic Policy on Anti-Bribery of Public Officials

For information on the prevention of bribery of public officials of NIPPON PAPER GROUP, please refer to the following basic policy.

• NIPPON PAPER GROUP Basic Policy on Anti-Bribery of Public Officials (Japanese only) [5.36KB]

Based on the provisions of the Group Missionand the Charter of Conduct and the spirit thereof, the NIPPON PAPER GROUP established a basic policy regarding the prevention of bribery of public officials and compliance with relevant laws and regulations in the countries concerned (including Japan).

1. Prohibition of bribery
   Officers and employees*2 of the NIPPON PAPER GROUP*1 shall not offer any form of bribery (regardless of the amount) to public officials*3, whether directly or indirectly*4.

2. Compliance with the laws and regulations of relevant countries
   Officers and employees of the NIPPON PAPER GROUP shall not provide, offer, or promise public officials entertainment, gifts, or other benefits that violate the laws and regulations of the relevant countries (including Japan), whether directly or indirectly.

3. Obligation to record
   If a public official is made with the intention of bribery and does not violate laws and regulations, all payments, entertainment, or gifts must be properly recorded*5.

4. Implementation of education and training
   Based on these Guidelines, NIPPON PAPER GROUP will regularly conduct education and training for officers and employees in order to prevent bribery of public officials and maintain the appropriateness of business execution.

Above

1. NIPPON PAPER GROUP: Refers to Nippon Paper Industries Co.,Ltd.and its subsidiaries (companies that control financial and business policy decisions, including indirect investment companies).

2. Officers and employees: Refers to directors andAudit & Supervisory Board Member, as well as executive officers, full-time employees,contract employees,part-time employeesdispatch employees, part-time employees, and other persons who have an employment relationship with NIPPON PAPER GROUP.

3. Public officials: Refers to persons holding legislative, administrative, and judicial positions, public institutions, public enterprises, public international organizations, and other equivalent persons.

4. Indirect bribery: Refers to bribery through third parties such as distributors, agents, consultants, etc.

5. Properly recorded: Refers to keeping accurate books and records with reasonable detail.

Established on November 8, 29