JT Group Human Rights Policy

Commitment to respect human rights
The JT Group 1 consists of businesses in the tobacco, pharmaceutical, and food industries, each of whichhas potential human rights impacts on stakeholders. We are committed to respecting human rights acrossour global operations as expressed in the International Bill of Human Rights 2 and the principles concerning
fundamental rights in the International Labor Organization’s Declaration on Fundamental Principles andRights at Work 3. We also commit to the United Nations Guiding Principles on Business and Human Rights4.
Respecting human rights is a fundamental element of delivering on our management principles as set outin our 4S model. The JT Group Human Rights Policy complements our Codes of Conduct and clarifies ourapproach to human rights elements within the Codes. The JT Group Human Rights Policy and the Codesof Conduct govern what we do and how we behave in our daily operations.
We require those who work within the JT Group companies, Members of the Board, suppliers and otherbusiness partners to comply with this Human Rights Policy.
We adhere to all applicable laws and regulations wherever we operate. Where national law andinternational human rights standards differ, we will follow the higher standard; where they are in conflict,
we will seek ways, including through third party partnerships, to respect international human rights to thegreatest extent possible.

Commitment to the continuing process of human rights due diligenceIn line with the United Nations Guiding Principles on Business and Human Rights, we will make humanrights due diligence an essential and integrated part of our business processes to identify and assess actualand potential human rights risks. We act upon the findings of our due diligence program to prevent andmitigate adverse human rights impacts and deliver appropriate and effective remedy.
Our existing practices will inform our human rights due diligence efforts. Currently, we have implemented
a number of programs addressing stakeholder concerns, including the following.
Our employee-related policies and standards promote responsible labor practices. We embrace
diversity and promote an inclusive culture where everyone can be themselves at work and enjoy asafe workplace without risk of discrimination or harassment. We do not tolerate discrimination
1 References to the ‘JT Group’ in this Policy are to Japan Tobacco Inc. and its consolidated subsidiaries.

2 The International Bill of Human Rights consists of the Universal Declaration of Human Rights, the International Covenant on Civiland Political Rights, and the International Covenants on Economic, Social and Cultural Rights. It is widely regarded as thefundamental human rights framework in the international community.
3 The ILO Declaration includes the principles concerning fundamental rights as enshrined in the eight core conventions, namely,
freedom of association and the effective recognition of the right to collective bargaining, the elimination of all forms forced orcompulsory labor, the effective abolition of child labor, and the elimination of discrimination in respect of employment andoccupation.
4 The United Nations Guiding Principles on Business and Human Rights, endorsed by the United Nations Human Rights Council in
2011, are the authoritative global standard for States and business enterprises to prevent and address the risk of adverse impacts
on human rights linked to business activity.

linked to gender, sexual orientation, age, race, religion, ethnic background, national origin,disability, marital status, or any other characteristic protected by law. We aim for open andconstructive relations with trade unions and works councils and support freedom of associationand the right to collective bargaining.
We have grievance channels to address potential concerns from our employees and otherstakeholders alike.
We apply strict quality control and marketing standards across our tobacco, pharmaceutical, andprocessed food businesses to fulfill our consumers’ expectations and behave responsibly.
We have established tailored programs in tobacco growing communities where we operate, which
aim to address child labor and workers’ rights issues, support good agricultural labor practices, andpromote growers’ sustainable incomes.
We are committed to engaging with relevant stakeholders to understand and address human rights
impacts linked to our business from the perspective of those affected.
We commit ourselves to communicating this Policy widely. We will also provide the necessary training sothat the appropriate people throughout our business operations have the knowledge and capacity topromote respect for human rights effectively.
We will track the effectiveness of our actions to identify and address impacts. We will report publicly ourprogress on implementing the Policy, at least annually.
We recognize that implementing the measures to respect human rights throughout our global operations
is an ongoing process. This Policy is only the first iteration of our commitment to do so. We will seek toupdate our Policy and practices as we move forward on our journey.

Masamichi Terabatake
Representative Director and President
Chief Executive Officer
Approved by Japan Tobacco Inc. Board of Directors, March 2022
This Policy is effective as of 1 April 2022 and supersedes any previous policies.