Sustainable Procurement Policy

The Pack Group Sustainable Procurement Policy

1．Purpose

The Pack Group Sustainable Procurement Policy sets forth basic principles for all procurement activities conducted by The Pack Group to fulfill its social responsibility throughout its entire supply chain, which forms the foundation of its business activities, and to contribute to the realization of a sustainable society. It serves as the basis for ensuring that the entire Group conducts procurement activities based on a consistent ethical standard and with consideration for the environment and society.

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. We strongly recognize the impact of our procurement activities on the environment and local communities and aim to build a sustainable supply chain through mutual understanding and cooperation with our suppliers. This policy has been formulated with reference to the United Nations Guiding Principles on Business and Human Rights, the core labor standards of the International Labour Organization (ILO), and other internationally recognized principles and norms concerning human rights, labor, the environment, and related topics.

3．Definitions

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” refer 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.
（3） “Suppliers” refer to all trading partners and business partners involved in the provision of raw materials, products, software, services, etc. (including their upstream supply chains).

４．Scope

This policy applies to all procurement activities conducted by The Pack Group. The Pack Group also expects all suppliers to understand the intent of this policy and to cooperate in establishing a sustainable business environment.

５．Requests to Suppliers (Conduct Principles)

We request our suppliers to implement the following initiatives to pursue sustainability throughout the entire supply chain. We shall work together to promote these initiatives:

（1）Working environments and respect for human rights (social considerations)
Suppliers are expected to support international human rights norms and respect the fundamental human rights of all workers, and to maintain safe, healthy working environments.

• ･Prohibition of child labor:We shall not permit the employment of persons of less than the statutory minimum employment age under any circumstances, and shall prohibit any labor that impedes the sound development of children.
• ･Prohibition of forced labor:We shall prohibit all forms of unjust labor conducted against people’s free will, and shall not permit any form of forced labor related to debt bondage or human trafficking.
• ･Prohibition of discrimination and harassment:We shall eliminate all types of discrimination based on nationality, race, religion, gender, age, disability status, sexual orientation, or other characteristics, and shall prohibit any form of physical, psychological, or sexual harassment and abuse.
• ･Respect for the right to collective bargaining and freedom of association: We shall respect workers’ freedom of association and the right to collective bargaining.
• ･Reduction of excessive working hours:We shall properly manage employee working hours and days off in compliance with applicable laws and regulations, and shall strive to reduce excessive working hours.
• ･Ensuring appropriate wage levels:In addition to compliance with statutory minimum wages, we shall strive to pay in excess of the minimum wages to ensure a living wage sufficient to cover employees’ cost of living.
• ･Ensuring health and safety:We shall comply with laws and regulations concerning occupational health and safety, implement measures and secure educational opportunities to prevent workplace accidents and disasters, and provide safe, sanitary working environments.

• ･Energy use and climate change mitigation: We shall make more efficient use of energy, seek to transition to renewable energy, and continuously reduce our impact on the climate, including our CO2 emissions.
• ･Prevention of environmental issues and pollution:We shall appropriately monitor and control emissions of pollutants into the air, water, and soil, and shall prevent environmental issues arising from our business activities.
• ･Optimization of resource use and waste reduction: We shall promote the effective use of raw materials and the adoption of recycled materials, and shall strive to reduce waste generated by our business activities and to ensure appropriate resource use.
• ･Proper management of water resources:Recognizing the importance of water resources, we shall strive to properly manage water intake and discharge volumes (i.e., by reducing water usage) and to preserve water quality.
• ･Consideration for impact on biodiversity:In our procurement of natural capital, including lumber and other forest resources, we shall strive to minimize our impact on ecosystems and biodiversity by acting to counter deforestation and by prioritizing the use of certified materials sourced from properly managed forests.

• ･Anti-corruption:We shall comply with all applicable domestic and international laws and regulations and prohibit all forms of corruption, including bribery, acceptance of bribes, and embezzlement for the purpose of obtaining unjust benefits.
• ･Thorough control of information: We shall rigorously control confidential information and personal information obtained through procurement activities and prevent improper leaks.
• ･Exclusion of antisocial forces and nonuse of conflict minerals: We shall completely sever any relationships with antisocial forces. In addition, we shall avoid all use as raw materials of conflict minerals that may serve as a source of funding for human rights violations or environmental destruction.
• ･Transparent and truthful disclosure:We shall provide the accurate and truthful disclosure of information regarding the state of legal and regulatory compliance, working environments, and initiatives related to human rights and the environment. We shall not submit false reports, alter records, or intentionally conceal material information.

• ･Ensuring quality and safety:We shall strive to ensure the quality and safety of products and services we provide and to continuously improve quality.
• ･Stable supply and compliance with delivery deadlines: We shall strive to provide a stable supply of products and services and to meet delivery deadlines, even in the event of a disaster or other unforeseen circumstances, based on business continuity plans (BCP).

６．Building Partnerships and Mutual Prosperity

Based on the Declaration of Partnership Building, a Groupwide commitment, The Pack Group shall not make unreasonable requests for cost reductions, and shall comply with desirable transaction practices in accordance with the standards for the promotion of subcontractors under the Act on the Promotion of Entrusted Small and Medium-sized Enterprises, including pricing decisions that allow for appropriate profits. We shall not make unilateral demands on suppliers, and shall aim to build a supply chain characterized by mutual prosperity based on mutual trust.

７．Education and Awareness

In order to promote sustainable procurement, The Pack Group shall provide regular training and education on this policy to all board members and employees involved in procurement activities. In addition, we shall take steps to ensure that all suppliers familiarize themselves with this policy and ask for their continued understanding and support.

８．Promotion Structure and Continued Monitoring

In order to ensure the effectiveness of this policy, we shall develop a promotion structure centered on the Sustainable Committee, under the oversight of the Board of Directors. We shall also implement regular monitoring of our suppliers’ initiatives. If any event that significantly violates this policy is identified, we shall engage in discussions for corrective action and improvement and cooperate to build a sustainable supply chain. Suppliers who do not consent to the intent of this policy or cannot demonstrate sufficient improvements in response to a correction request may be subject to revision of transaction conditions or discussion of whether to continue transactions.

９．Publication

This policy shall be made public both internally and externally to promote highly transparent procurement activities.

Naoki Nakamura, President and CEO
THE PACK CORPORATION
Date of enactment: June 1, 2026 (Ver. 1.0)