Code of Conduct

The Pack Group Code of Conduct

1．Purpose

The purpose of The Pack Group code of conduct is to stipulate the basic rules which form the standards for conduct and judgement by which the group’s board members and employees must abide, in order for the group to achieve sound development by complying with laws and abiding by the sound judgement of society within the business activities in which it is involved.

2．Definition

The definitions for the terms in this code of conduct are as follows.

（1）“The Pack Group” refers to THE PACK CORPORATION and consolidated subsidiary companies.
（2）“Board members and employees” refers to the directors, corporate auditors, corporate officers, advisors, consultants, and employees (including full-time employees, continuing employees, contract employees, temporary employees, part-time employees, and casual employees) of all companies of The Pack Group.

3．Fundaments

（1）Compliance with laws and regulations
As an enterprise, The Pack Group is subject to the responsibilities of any member of society, and as such shall comply with internal and external laws and regulations and abide by the sound judgement of society in carrying out its business activities.
・The Pack Group obtains licenses and permits required for business activities and submits registrations and notices appropriately.
・The Pack Group monitors applicable laws and regulations, including revisions and terminations, and confirms that no business transactions or internal activities violate laws or regulations.
・The Pack Group does not tolerate any activities to cooperate with or involved in money laundering and will take the necessary measures to prevent such activities.
・When a violation has occurred or there is a suspicion of a violation, The Pack Group takes corrective actions promptly and implements measures to prevent the problem from happening again.
・As needed, The Pack Group sends notices and provides training programs to board members and employees to make everyone aware of the importance of compliance with laws and regulations.

（2）Respect and protection of human rights
The Pack Group shall carry out its management with respect for human rights, whether inside or outside of the company.
・The Pack Group is an equal opportunity employer that does not discriminate with respect to race, nationality, religion, gender, age, disabilities or other characteristics.
・The Pack Group is dedicated to upgrading frameworks and management systems that reject child labor and forced labor and prevent violence, harassment, bullying, psychological torment and other disruptive workplace behavior.
・The Pack Group respects the right of employees to organize for the purpose of holding labor-management discussions involving the workplace environment, wages and other subjects.
・The Pack Group is dedicated to upgrading systems that enable board members and employees to achieve their full potential while maintaining the proper balance between their jobs and private lives as well as to providing support to individuals to develop and improve their skills.
・The Pack Group contributes to the health of its board members and employees by providing safe workplaces that make it easy for people to work at their best.

（3）Contribution to the environment
The Pack Group shall proactively carry out its responsibilities as a business with respect to global environmental protection, which is an issue shared by the entire world.
・The Pack Group conducts business activities in accordance with the Basic Environmental Policies that reflect the group’s environmental philosophy.
・The Pack Group establishes numerical environmental targets and announces the results of activities to accomplish these targets.
・The Pack Group has established a fund for forest conservation activities and conducts these activities with customers, non-profit organizations, government agencies and residents of nearby communities.

（4）Social contribution
The Pack Group recognizes the role and responsibility of a business within society, and shall proactively carry out social contribution activities.
・The Pack Group plays a role in the growth and advancement of the culture of packaging by creating new types of packaging and new packaging technologies.
・As a member of local communities, The Pack Group will continuously conduct activities for maintaining and reinforcing lines of communication with the nearby communities.
・The Pack Group operates programs to support the volunteer activities of board members and employees.

４．Business Activities

（1）Customer first principle
The Pack Group shall seek to understand the needs of clients as well as consumers, and develop and provide useful products and services to society.
・The Pack Group concentrates its knowledge for the development of products and services with new value for the purpose of enabling sales, development, manufacturing, distribution, administration and all other business units to satisfy clients and consumers.
・The Pack Group is dedicated to improving quality in order to provide clients and consumers with products and services that are safe and highly appealing.

（2）Business partners
The Pack Group shall conduct equal and fair transactions with business partners that supply materials, goods and services.
・The Pack Group abides by all rules that apply to the free and fair transactions with business partners and will not tolerate improper transactions, such as taking advantage of a superior position. The group abides by all applicable laws, regulations, and contracts with sincerity when conducting transactions.
・The Pack Group is committed to avoiding bribery and corruption based on positions in business and assures equal partnerships and fairness in all its transactions.
・The Pack Group provides thorough training to employees who handle its transactions to safeguard against conflicts of interest.
・To achieve mutual growth and development with business partners, The Pack Group builds and strengthens sound business relationships that are based on the spirit of mutual trust and cooperation.
・The Pack Group uses dialogues with business partners to improve quality in order to contribute together to the growth and advancement of the packaging industry.

（3）Competitors
With regard to competing companies, The Pack Group engages in fair and open business activities based on respect for the principle of free competition and full compliance with antitrust and other applicable laws and regulations.
・The Pack Group refrains from improper transactions and other such actions, including clandestine agreements and price collusion with competitors. Drawing on its technologies, product and service development capabilities, and sales skills, the group pursues its business activities in a fair and transparent manner.
・The Pack Group never engages in activities that take advantage of the secrets of competitors and never slanders the products of competitors.

（4）Business within the group
Regarding collaborations and business conducted between all companies within the group, The Pack Group shall act within fixed standards and strive for sound practice across the entire group, in order to maintain the good faith of society.
・Companies in The Pack Group recognize each other’s autonomy and conduct fair business transactions based in transparent relationships.
・To strengthen synergies within The Pack Group, group companies seek to identify their respective strengths and to work jointly to achieve progress and sustained growth for the overall group.

（5）Intellectual property
The Pack Group shall respect intellectual property, including licenses, new practical models, designs, trademarks, copyright and trade secrets.
・The Pack Group aggressively acquires and uses intellectual property rights that are required for business activities.
・Intellectual property rights acquired are properly maintained and managed and suitable measures are implemented regarding any infringement on intellectual property rights by third parties.
・The Pack Group respects third-party intellectual property rights and does not utilize these rights in a fraudulent or improper manner.

（6）Anti-social influences
The Pack Group shall reject and in no way conduct business with, or serve the interests of anti-social influences and activities.
・The Pack Group rejects any involvement of anti-social influences in business activities and will resolutely reject any improper demands.
・The Pack Group works with other organizations to eliminate anti-social influences.
・Contracts with business partners and clients include a provision requiring the elimination of anti-social influences.

（7）Information management
The Pack Group shall strictly manage the confidential information of clients and business partners, as well as of The Pack Group, learned in the course of business (the “confidential information”), and ensure that it is not leaked to third parties or used for any purposes other than business.
・Confidential information is disclosed only by using the designated procedure.
・Confidential information is never used improperly, such as in a manner that would be harmful to the company or that would yield benefits for an individual or any other third party.
・Confidential information is protected and used properly in accordance with rules for the management of information.
・Board members and employees do not reveal to the company any confidential information that they acquired prior to joining The Pack Group.
・The Pack Group has safety measures for preventing leaks and other problems and implements corrective measures promptly in the event of an accident involving confidential information.

（8）Insider trading
The Pack Group shall suitably manage the insider information of other companies, as well as of The Pack Group, learned in the course of business.
・Insider trading using facts, plans or other information that has not been disclosed to the public is prohibited.
・Information about The Pack Group is properly disclosed to the public as needed in compliance with timely disclosure rules.
・The Pack Group understands that leaks of important information can have a significant negative effect on society and takes actions to manage this information properly.

５．Internal Controls

The Pack Group will establish an effective and appropriate internal management structure, in order to make decisions and conduct business activities in compliance with the law and sound judgment of society.