Ethics Policy
The Pack Group Ethics Policy
1．Purpose
The Pack Group Ethics Policy sets forth the basic principles of corporate ethics and compliance with laws and regulations for The Pack Group, and establishes the foundation upon which the entire Group conducts its business activities based on a consistent ethical framework.
2．Basic Philosophy
The Pack Group shall conduct its business activities in a fair and transparent manner based on a high ethical standard, with the aim of realizing its corporate motto—Passionate and Dedicated to Our Partnerships—and the purpose of its existence—Mission to bolster social prosperity and create satisfaction through packaging. Beyond simply complying with laws and regulations, we shall continue to act with the sound judgement of society and with integrity and earn the trust of all our stakeholders.
3．Definition
The definitions of terms used in this policy 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 within The Pack Group.
４．Scope
This policy applies to all board members and employees of The Pack Group. The Pack Group also expects its business partners to understand the intent of this policy and cooperate in building an ethical business environment.
５．Conduct Principles
We shall uphold high ethical standards and act with integrity in accordance with the following principles:
（1） Complete elimination of bribery and corruption
We shall not give or receive money, gifts, entertainment, or any other benefits for the purpose of obtaining improper advantages, regardless of whether the counterpart is a public official or a private individual. We also prohibit small payments made to expedite administrative procedures (facilitation payments).
（2）Prohibition of fraud and misconduct
We shall not engage in any form of misconduct, including embezzlement of Company assets, fictitious billing, accounting fraud, and other fraudulent actions.
（3）Avoidance of conflicts of interest
We shall not engage in any act that creates conflict between Company and individual interests by taking advantage of our position. We shall promptly disclose any potential conflicts of interest to the Company.
（4）Fair competition and relationships with competitors
We shall comply with antitrust and other applicable laws and regulations and eliminate illegal transactions such as bid-rigging and price collusion. In addition, we shall not engage in any actions of defamation or slander against competitors or their products.
（5）Respect for intellectual property rights
We shall respect the patents, trademarks, copyrights, trade secrets, and other intellectual property rights of other companies and refrain from any actions that infringe on or constitute the abuse of such rights. We shall also manage and utilize Company intellectual property appropriately.
（6）Appropriate management of intra-Group transactions
We shall respect the independence of each Group company and maintain a certain level of discretion and distance with each other to build fair and transparent relationships that do not give rise to any suspicion from society.
（7）Elimination of anti-social forces and prevention of money laundering
We shall not provide any benefits to anti-social forces and shall sever any ties to them. In addition, we shall not tolerate any cooperation or involvement in the transfer of criminal proceeds (money laundering).
（8）Information management and prevention of insider trading
We shall strictly mange confidential and personal information and prevent its use for purposes other than those intended or its leakage. In addition, we shall not engage in insider trading based on unpublished material facts.
６．Education and Awareness
In order to strengthen ethical awareness, we shall provide regular training and education to all board members and employees. We shall ensure that this policy is thoroughly communicated throughout the Company and obtain signed letters of consent from all board members and employees.
７．Promotion Structure
In order to ensure the effectiveness of this policy, we shall establish a framework centered on the Sustainable Committee, under the oversight of the Board of Directors, and promote the enhancement of ethical awareness and compliance across the entire Company through each department.
８．Whistleblowing System and Disciplinary Action
（1）Whistleblowing channels and protection of whistleblowers
For early detection and rectification of any actual or potential violations of this policy, The Pack Group has established its C Line internal and external (attorney-based) whistleblowing and consultation channels. These channels are intended to detect and rectify any improprieties or problems at an early stage. Furthermore, we handle all consultations in the strictest confidence and take every precaution to protect the privacy of whistleblowers so that they do not suffer any disadvantageous treatment from the Company.
（2）Disciplinary action
Board members and employees found to be in violation of this policy or related laws and regulations are subject to strict disciplinary action, including disciplinary dismissal. Furthermore, if any violation causes damage to the Company, the Company may take legal action and demand compensation for damages.
９．Publication
This policy shall be made public both internally and externally.
Naoki Nakamura, President and CEO
THE PACK CORPORATION
Date of enactment: May 1, 2026 (Ver. 1.0)