TOPPAN Group
Sustainable Procurement Guidelines
Version 3.1

October 1, 2023

TOPPAN Holdings Inc.

Contents

Introduction
The Structure and Positioning of the Guidelines
TOPPAN Group Sustainable Procurement Guidelines

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4
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Basic Procurement Policy
Sustainable Procurement Standards

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1.Legal Compliance and Respect for Internationally Recognized Standards

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2. Human Rights and Labor(2-1) Prohibition of Forced Labor(2-2) Prohibition of Child Labor and Respect for the Rights of Young Workers(2-3) Management of Appropriate Working Hours(2-4) Payment of Appropriate Wages(2-5) Prohibition of Inhumane Treatment(2-6) Prohibition of Discrimination(2-7) Freedom of Association and Right to Collective Bargaining(2-8) Consideration for Job Security and Fulfillment of the Obligations of an Employer(2-9) Prohibition of Infringing on the Rights of Local Communities, etc.

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3. Health and Safety(3-1) Maintaining Occupational Health and Safety(3-2) Emergency Preparedness(3-3) Occupational Injury and Illness(3-4) Industrial Hygiene(3-5) Physically Demanding Work(3-6) Machine Safeguarding(3-7) Health and Safety at Facilities(3-8) Health and Safety Communication(3-9) Worker Health Management9

4. Environment(4-1) Environmental Permits and Reports(4-2) Contributing to Decarbonization(4-3) Air Emissions(4-4) Optimal Water Use(4-5) Contributing to Resource Circulation(4-6) Management of Hazardous Substances(4-7) Managing the Chemical Substances Contained in Products(4-8) Natural Resources and Biological Diversity

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5. Fair Business and Ethics(5-1) Preventing Corruption(5-2) Prohibiting Provision and Acceptance of Inappropriate Benefits(5-3) Disclosure of Information(5-4) Protecting and Respecting Intellectual Property(5-5) Fair Business Activities(5-6) Protecting Whistleblowers(5-7) Responsible Minerals Procurement

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6.Quality and Safety(6-1) Product Safety(6-2) Quality Management(6-3) Providing Accurate Information on Products and Services

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7.Information Security(7-1) Defense from Cyber Attacks(7-2) Protecting Personal Information(7-3) Preventing the Leak of Confidential Information

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8.Business Continuity Planning(8-1) Developing and Preparing a Business Continuity Plan

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9.Establishing a Management System(9-1) Establishing a Management System(9-2) Management of Suppliers and Contractors(9-3) Proper Import and Export Controls(9-4) Establishing Grievance Mechanisms

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Revision History

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Introduction
The TOPPAN Group aims to contribute to the sustainable growth of society. To
this end, we promote sustainable procurement activities, whereby corporate social
responsibility (CSR) activities are extended throughout the entire supply chain incooperation with our suppliers and contractors (hereinafter referred to as “Business
Partners”). Through these activities, we also aim to enhance the corporate value of
the TOPPAN Group as well as our Business Partners.
Specifically, we have been conducting sustainable procurement activities by
establishing the first version of the TOPPAN Group CSR Procurement Guidelines
in 2007, which was then revised in 2014. However, in light of recent trends withregard to sustainable procurement, such as the establishment of international
standards and social demands, we have now renamed the guidelines as the
TOPPAN Group Sustainable Procurement Guidelines (hereinafter referred toas the “Guidelines”) and revised the standards. We greatly appreciate yourunderstanding of the purpose and content of the new Guidelines and kindly ask
for your cooperation with the TOPPAN Group’s sustainable procurement activities.

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The Structure and Positioning of the Guidelines
The Guidelines consist of the Basic Procurement Policy and a set of Sustainable
Procurement Standards. The Guidelines are applied to the procurement activitiesof each company of the TOPPAN Group when it procures any goods or services
necessary for its business activities by means of purchasing, leasing, or otherwise.
As such, the Guidelines shall not only be applied to the procurement activities ofprocurement departments, but also to the procurement/purchasing activities of all
departments of each company of the TOPPAN Group. The Guidelines, however, do
not apply to financing activities.

Basic Procurement Policy
This is a basic policy that applies to all workers involved in procurement activities at the TOPPANGroup.

Sustainable Procurement Standards
The Sustainable Procurement Standards are comprised of nine sections including legal complianceand respect for internationally recognized standards; human rights and labor; health and safety,
environment; fair business and ethics; quality and safety; information security; business continuity
planning; and establishing a management system.
In this document, the descriptions in the square boxes set out requirements for Business Partners.
Below the square boxes are recommendations, supplementary information for understanding therequirements, and reference information to achieve higher standards exceeding the requirements.
In addition to meeting these requirements, the basic principle for doing business with ourBusiness Partners is that Business Partners inform their suppliers and contractors of the Guidelines
or of their own similar guidelines so that the details of the Guidelines are passed further up
the supply chains. We may ask to conduct due diligence (investigation and assessment prior tostarting business transactions) or audits of Business Partners or their suppliers and/or contractors
to confirm compliance with items stipulated in the Guidelines. Cooperation from each of ourBusiness Partners is greatly appreciated.
Definitions of Terms

Employee and Worker• The term “employee” refers to a person who is directly entered into a labor contract with a company.
This includes persons such as full-time employees, part-time employees, fixed-term contract employees,
and short-term part-time employees.
• The term “worker” refers to anyone who works in any form of employment including “employees” aswell as workers in other forms of employment or working style (temporary workers, contract workers,etc.).

Supply chain
Supply chain refers not only to the process starting from raw materials and ending when products andservices arrive at consumers, but to all relationships including worker dispatch agents and contractors,
regardless of the individual roles of each company.

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TOPPAN Group Sustainable Procurement Guidelines
Basic Procurement Policy• We fairly and impartially offer opportunities to all Business Partners andpotential Business Partners.
• We comply with domestic and overseas laws and regulations and conduct fairbusiness transactions based on corporate ethics.
• We strictly control the information obtained through procurement activities.
• We work to conserve the environment and reduce impact on the environment.
• We pursue QCD (Quality, Cost, Delivery) in order to meet the needs of themarket.
• We work to foster mutual cooperation and build relationships of trust with
Business Partners.
• We promote sustainable procurement throughout the entire supply chain.

Sustainable Procurement Standards
1. Legal Compliance and Respect for Internationally RecognizedStandards
Conduct business activities in compliance with the laws and regulationsof each country and region, and with respect for internationallyrecognized standards.
Business activities should be conducted with an understanding of, and in compliance with,human rights, labor, environmental and ethics standards, and other relevant laws andregulations in the countries and regions where the business is conducted. When conducting
business activities, Business Partners must be aware that there are cases in which not only
the laws and regulations of their home countries or the country or region where they
operate but also the laws and regulations of a third country apply. Business Partners are also
required to ensure compliance with laws and regulations not only at their own company but
throughout the supply chain, and to respect internationally recognized standards.
Internationally recognized standards refer to expectations for socially responsible businesspractices, guided by customary international law, generally-accepted principles ofinternational law, and universal intergovernmental agreements (including conventions andtreaties). This corresponds to documents such as the Guiding Principles on Business andHuman Rightsⅰ and the Sustainable Development Goals (SDGs) of the United Nations,ⅱ the
Guidelines for Multinational Enterprises of the Organization for Economic Co-operation andDevelopment (OECD),ⅲ and the Tripartite Declaration of Principles Concerning Multinational
Enterprises and Social Policy (MNE Declaration) of the International Labour Organization (ILO).ⅳ

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2. Human Rights and Labor
Business Partners should respect the human rights of all people involved in theircorporate activities and ensure that their activities do not directly or indirectly
infringe on human rights.

(2-1) Prohibition of Forced Labor
Respect the right of workers to work of their own free will and to terminate
their employment voluntarily. Do not use labor obtained through force,slavery, or human trafficking, or use bonded labor (including debt bondage)
or exploitative prison labor.
Forced labor refers to involuntary labor provided under the threat of penalty. This includes
transporting, harboring, recruiting, transferring, or receiving persons by means of threat,
force, coercion, abduction or fraud for labor or services. Bonded or indentured laborrefers to labor that workers cannot voluntarily terminate and includes debt bondage.
Furthermore, workers shall be free to terminate their employment without penalty or
punishment if a reasonable period of notice is given as per the worker’s contract.

(2-2) Prohibition of Child Labor and Respect for the Rights of Young
Workers
Do not employ or allow work by children who are under the minimum
working age governed by local laws and regulations. Do not allow young
workers under the age of 18 to perform hazardous work that is likely tojeopardize their health or safety.
In Japan, a child shall not be employed before April 1 after reaching the age of 15.
Furthermore, if a minimum working age or an age for completing compulsory education
is higher than the age of 15 in local laws and regulations, Business Partners should not
employ persons who are under that age. Moreover, Business Partners should protect thehealth and safety of workers under the age of 18 in particular, and should not allow such
workers to perform hazardous work.
Under the provisions of ILO Recommendation No. 190 (1999), hazardous work refers to:• work which exposes children to physical, psychological or sexual abuse;• work underground, under water, at dangerous heights or in confined spaces;• work with dangerous machinery, equipment and tools, or which involves the manual
handling or transport of heavy loads, or work in an unhealthy environment whichmay, for example, expose children to hazardous substances, agents or processes, orto temperatures, noise levels, or vibrations damaging to their health; and• work under particularly difficult conditions such as working for long hours or during
the night, or work where the child is unreasonably confined to the premises of theemployer.

6(2-3) Management of Appropriate Working Hours
Do not allow workers to work beyond the working hour limits provided for in
local laws and regulations. At the same time, appropriately manage workers’
working hours, days off, and leave, taking internationally recognized
standards into consideration.
Business Partners should appropriately assign working hours and days off and grant leavebased on each country’s laws and regulations. Business Partners are also expected toconsider internationally recognized standards. For example, the ILO’s convention (No. 14,
No. 106) provides for the granting of at least one day off (at least 24 hours) every sevendays. The Responsible Business Alliance (RBA), an international coalition dedicated tocorporate social responsibility in the electronics industry, has set the maximum working
hours, including overtime, at 60 hours per week. Appropriate management means thatthe number of prescribed working days per year does not exceed the legal limit andthe number of working hours per week (excluding during disasters, other unavoidable
emergencies or unusual situations) including overtime does not exceed the legal limit.
It also ensures that the right to annual paid leave, maternity leave, and childcare leave
provided for in laws and regulations is granted, rest periods as provided for in laws andregulations are granted, and that physical and mental health examinations are conductedto protect the health of workers.

(2-4) Payment of Appropriate Wages
Compensation paid to workers must comply with rules pertaining to theminimum wage, overtime, and statutory benefits, etc. provided for in local
laws and regulations. Provide pay slips in workers' native language or in amanner that they can sufficiently understand. Pay slips should include sufficient
information to enable workers to confirm the exact compensation for the work
they performed in each pay period.
The minimum wage provided for in local laws and regulations should be paid, and overtime
wages should be paid in accordance with laws and regulations and employment contracts.
Conditions relating to wages and the details of wages should be provided to workers as
information, and wages should not be unfairly reduced. Business Partners are also expectedto pay wages at a level that allows workers to support their basic needs (a living wage).

(2-5) Prohibition of Inhumane Treatment
Respect the human rights of workers and take preventative measures as anorganization on top of prohibiting the treatment of workers in a manner thatis or may be construed to be inhumane, including physical and psychologicalabuse, coercion, or harassment.
Psychological abuse refers to the act of causing mental or emotional harm to others
through acts such as inhumane language or expressions, harassment, neglect, or words
that damage one’s self-esteem. Physical abuse refers to violence and work under harshconditions. Coercion refers to the act of forcing others to do something against their willthrough intimidation, etc., such as forcing workers to work overtime. Harassment refers
to the act of making others feel unpleasant due to pestering or bullying.
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(2-6) Prohibition of Discrimination
Do not discriminate on the basis of race, ethnicity, nationality, religion, age,physical characteristics, disabilities, gender, marital status, sexual orientation,or gender identity, etc.
Disparities in hiring, training, evaluations, and treatment based on factors other thanreasonable factors such as an individual’s ability, aptitude, and performance, constitutean act of discrimination. The loss of equal opportunity or fair treatment due to theoutcome of health checks and pregnancy tests is also regarded as discrimination.

(2-7) Freedom of Association and Right to Collective Bargaining
Respect the rights of workers to form and join trade unions and to bargain
collectively, in compliance with local laws and regulations.
Business Partners should respect the right of workers to freely choose to form and join tradeunions and participate in collective bargaining. Business Partners should provide opportunities
for effective communication between workers and management to properly ensure suchrights, and should further ensure an environment where workers and their representatives
can engage in collective bargaining to facilitate worker-initiated communication in goodfaith with management regarding concerns about working conditions and management
practices, without fear of discrimination, retaliation, intimidation, or harassment.

(2-8) Consideration for Job Security and Fulfillment of the Obligations ofan Employer
Give consideration to employment stability and fulfill obligations as an
employer, such as arranging for social security provided for in local laws andregulations.
In order to provide employees with the most stable employment possible, Business
Partners should fulfill their obligations concerning job stability based on freely negotiatedworking conditions and social security. Business Partners should fulfill a key role inpromoting employment security in countries where the cessation of their operations
could lead to long-term unemployment. Business Partners are also expected to avoid
undertaking arbitrary dismissal procedures and to provide stable employment for
employees through active workforce planning.

(2-9) Prohibition of Infringing on the Rights of Local Communities, etc.
Do not infringe on the rights of local communities and indigenous peoples,such as engaging in unlawful eviction or the significant destruction of theirliving environment.
When acquiring or using, etc. land for business activities, Business Partners should comply
with local laws and regulations. In addition to complying with laws and regulations,
Business Partners are expected to gain the understanding of affected local communities
and indigenous peoples. For example, the Business Reference Guide to the UN
Declaration on the Rights of Indigenous Peoplesⅴ recommends obtaining the Free, Priorand Informed Consent (FPIC) of indigenous peoples affected by the business activity.
83. Health and Safety
Business Partners should provide a safe and hygienic environment for workplaces,
including accommodations if they provide employees with such facilities. Business
Partners should also provide training and take measures to prevent potential
accidents, and should be prepared for accidents.

(3-1) Maintaining Occupational Health and Safety
Assess occupational health and safety risks and maintain safety throughappropriate design, technology, and management measures. Appropriate
care should be taken to eliminate or mitigate occupational health and safety
risks, especially for pregnant women and nursing mothers.
Business Partners should identify safety hazards in the workplace and their risk ofoccurrence, and implement safety measures for workers. Examples of safety hazards
in the workplace include contact with chemical substances, electricity, or other energy
sources, and fire, vehicular accidents, and fall hazards. Business Partners should takereasonable steps to protect pregnant women and nursing mothers.

(3-2) Emergency Preparedness
Identify and evaluate all possible emergency situations such as natural
disasters and accidents in order to protect the life and safety of workers.
Establish emergency plans and procedures, install the required equipment
and conduct training to minimize harm to workers’ lives, the environment,
and property.
Emergency plans refer to, for example, emergency reporting, communication to workers,
clarifying evacuation procedures, installing evacuation equipment, ensuring easily
identifiable exits without obstruction, providing appropriate exit facilities, storing medical
supplies for emergency, installing fire detection systems, installing fire extinguishers, fire
shutters, and sprinklers, securing external communication methods, and maintaining
recovery plans. Business Partners should also disseminate emergency plans within theworkplace. This involves, for example, providing emergency training (including evacuation
drills) to workers, and placing/posting information on emergency procedures in an easily
accessible location in the workplace.

(3-3) Occupational Injury and Illness
Identify, assess, record, and report the status when workers suffer
occupational injury or illness, and implement appropriate countermeasuresand corrective measures.
Countermeasures and corrective measures for occupational injury or illness correspond tosystems and measures for promoting workers reporting, classifying and recording injury andillnesses, providing medical treatment when necessary, investigating injury and illnesses,
implementing corrective actions to eliminate causes, and facilitating the return to work ofworkers. This also includes implementing the required administrative procedures provided
for by laws and regulations and taking out industrial accident insurance.
9(3-4) Industrial Hygiene
Identify, assess, and appropriately control the risk of workers being exposed
to hazardous biological, chemical, or physical agents in the workplace.
Hazardous agents include substances that are poisonous, radioactive, or cause chronic
illness (such as lead and asbestos). Noise and odors may be deemed hazardous to thehuman body if they are significantly strong. Exposure means a person or organism
coming into contact with a hazardous substance such as a chemical substance, androutes of exposure include inhalation through breathing, oral exposure through food anddrink, and dermal exposure through contact with the skin.ⅵ Appropriate control refers
to establishing and implementing management standards, and providing appropriate
education and training and personal protective equipment to workers.

(3-5) Physically Demanding Work
Identify and assess physically demanding work and appropriately control
such work so that it does not lead to occupational injury and illness.
Physically demanding work refers to manual handling or repetitive lifting of heavy loads,
prolonged standing, and highly repetitive assembly or physically demanding assembly
work. Appropriate management includes providing a working environment basedon human engineering, regular breaks, supportive tools, and ensuring sharing andcooperation among multiple workers in regard to duties.

(3-6) Machine Safeguarding
Assess safety risks of the machinery used by workers and provide
appropriate safeguarding.
Appropriate safeguarding refers to management for preventing accidents and injuries
that occur during work. This can include safety mechanisms such as failsafe, foolproof,
interlock, and tagout; installing safety devices and putting protective barriers in place;and regular inspection and maintenance of machinery.

(3-7) Health and Safety at Facilities
Ensure appropriate health and safety at facilities such as cafeterias, watersupply facilities, toilets, and dormitories provided for workers. Ensure there
are appropriate emergency evacuation routes and emergency exits at thefacilities.
Business Partners should provide safe drinking water, hygienic food, and a sufficientnumber of clean toilet facilities proportionate to the number of workers. Dormitories
should have appropriate emergency exits, and are expected to be maintained to be cleanand safe, have adequate lighting, heating, and other appropriate facilities, and havereasonable space.

10(3-8) Health and Safety Communication
Provide training and appropriate health and safety information regarding
various hazards that workers are exposed to in the workplace using workers'
native language or a language and methods that they can sufficiently
understand. Establish a system that enables workers to provide feedback on
health and safety.
Workplace hazards that workers are exposed to include mechanical, electrical, chemical,
fire, and physical hazards. Occupational health and safety information should be clearly
posted in facilities or placed in a location identifiable and accessible by workers andshould be provided in workers' native language or a language that they can sufficiently
understand. Training should be provided to all workers before starting work and regularly
after that. A system should be put in place that enables workers to raise concerns without
retaliation.

(3-9)		Worker Health Management
Comply with local laws and regulations and provide appropriate healthmanagement to all workers.
Business Partners should conduct health checks to the level provided for by laws andregulations as a minimum, and work on the prevention and early detection of worker
illness. Business Partners are also expected to adequately consider the prevention ofhealth problems due to overwork and treatment such as mental healthcare.

114. Environment
Business Partners should comply with local environmental laws and regulations,and strive to prevent pollution of air, water, and soil. They should continuously
measure and assess the use and discharge of resources and strive to reduce impacts
on the environment.

(4-1) Environmental Permits and Reports
Obtain permits and approvals required for conducting business and comply
with requirements concerning management and reporting, in accordancewith local laws and regulations.
Business Partners should obtain all necessary environmental permits and licenses, including
operating permits and those concerning air emissions, wastewater, the storage and use ofhazardous substances, and waste (individual and hazardous) disposal. Depending on thechemical substances used in their business, Business Partners may be obligated to assign
a manager responsible for poisonous and deleterious substance management, designatedchemical substance management, or hazardous substance management. Dependingon the type of business conducted and the location of plants, Business Partners may berequired to obtain government approval for facilities that handle hazardous substancesand environmental impact assessments. Business Partners should properly update permits,registrations, or licenses obtained and retain a copy of the latest version.

(4-2) Contributing to Decarbonization
Strive to improve energy efficiency and make continuous efforts to reduceenergy consumption and greenhouse gas emissions.
Improving energy efficiency involves minimizing energy consumption and the related
Scope 1 (greenhouse gas directly emitted by a company) and Scope 2 (greenhouse gas
indirectly emitted by the use of electricity, heat, and steam provided by another company)
greenhouse gas (GHG) emissions. Business Partners are expected to track and document
energy efficiency at each facility or business site.

(4-3) Air Emissions
Comply with local laws and regulations, monitor the emission of hazardous
substances to the atmosphere, and implement appropriate countermeasuresprior to their discharge.
Hazardous substances discharged to the atmosphere include volatile organic chemicals(VOC), aerosols, corrosives, microparticles, ozone depleting substances, and combustion
byproducts. Business Partners should analyze and monitor these substances prior todischarge, and only discharge them after conducting the required control and treatment
based on the results of the analysis and monitoring. Countermeasures include routine
monitoring of the handling of substances to be discharged and the performance oftreatment systems.
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(4-4) Optimal Water Use
Comply with local laws and regulations, monitor the source, usage, anddischarge of water used, and save water. Test the quality and properties as
required, and monitor, control, and process all wastewater before discharge
or disposal. Identify and appropriately manage sources of pollution that may
cause water contamination.
Business Partners should monitor water sources, usage, and discharge, and conserve
water and control channels of contamination. Controlling channels of contamination
includes confirming that site water channels are free from contamination and areprotected from contamination (such as confirming that there are no pools of standing
water and grease/oil slicks near storm drains) and that the emergency response
equipment is in place. (Shutoff valves and stopcocks must be installed to prevent outflow
or leakage of clean water and sewage, including pollutants, due to a plant accident or
natural disasters. Street inlets/sewage inlets and storage reservoirs installed to containleaks or overflows are not sufficient.)(4-5) Contributing to Resource Circulation
Comply with local laws and regulations and promote the 3Rs (reduce, reuse,
and recycle), ensure the effective utilization of resources, and minimize
waste.
Business Partners should identify and manage waste even when disposing of waste
identified as non-hazardous, implement a systematic approach for responsible disposal
or recycling, and work towards reducing waste. Business Partners should implement
measures for disposing of substances according to local laws and regulations, and ensurethat natural resources are not wasted by minimizing their disposal. Measures include
changing the production equipment at the source, using alternative materials, andreusing and recycling resources. Business Partners should also establish voluntary targets
in order to comply with laws and regulations. Natural resources refer to water, fossil
fuels, minerals, virgin forest, and the products of virgin forest, etc. The prevention ofenvironmental pollution leads to the saving of natural resources and is closely related tothe sustainability of the planet.

(4-6) Management of Hazardous Substances
Comply with local laws and regulations to identify, label, and manage
chemical and other substances posing a hazard to humans or theenvironment, and manage accordingly to ensure the safe handling,transport, storage, use, recycling, reuse, and disposal of such substances.
Hazardous substances, including waste, should be properly separated and clearly
identified as hazardous, and access to hazardous substances should be controlled toensure proper handling, transfer, storage, use, recycling or reuse, and disposal. Business
Partners should use a legitimate business for disposal, such as a licensed or registeredprocessing or disposal company.

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(4-7) Managing the Chemical Substances Contained in Products
Comply with all laws, regulations, and TOPPAN Group standards that
apply to the prohibition and restriction of specific substances contained in
products.
In regard to substances contained in products, companies should follow the relevant
TOPPAN Group standards and the laws and regulations of the product’s country of origin
and destination. Upstream companies in the supply chain should provide the required
information to downstream companies in order to take responsibility for the components
included in the end products. Refer to the TOPPAN Group Standards for the Managementof Chemical Components of Raw Materials for specific details.

(4-8) Natural Resources and Biological Diversity
When procuring raw materials, avoid or minimize the impact on biologicaldiversity and work toward the sustainable use of natural resources.
When using resources derived from forests, oceans, or living organisms, etc., Business
Partners should avoid the use of resources that have been illegally extracted, cultivated,or traded. Business Partners are also expected to take resource conservation into
consideration when using raw materials, including from the perspective of controllingdeforestation and forest degradation. Since business activities may affect variousorganisms and their habitats, Business Partners are also expected to mitigate any adverse
impacts. If there is a possibility that rare plants and animals are used, the impact on
biological diversity can be mitigated by checking the raw materials, their origin, andthe existence of relevant regulations and resource conservation measures. Refer to the
TOPPAN Group Paper Procurement Guidelines for the Sustainable Use of Forest Resources
for details regarding sustainable paper procurement.

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5. Fair Business and Ethics
Business Partners should conduct business activities based on high ethical standards
in addition to complying with laws and regulations. This includes the prohibitionof bribery, corruption, inappropriate provision and acceptance of improper
benefits, coercion, and embezzlement, and the prevention of such acts.

(5-1) Preventing Corruption
Do not engage in any form of bribery, blackmail, or embezzlement.
Business Partners should uphold a policy of prohibiting any and all forms of bribery,
excessive entertainment or gifts, blackmail, or embezzlement, and maintain continuous
compliance. Continuous compliance requires not only establishing policies, but also
appropriately training employees and continuing to ensure that such policies are
implemented.

(5-2) Prohibiting Provision and Acceptance of Inappropriate Benefits
Do not provide or accept promises, proposals, or permissions that lead to the
granting or receipt of unfair or inappropriate benefits.
Business Partners are prohibited from directly or indirectly providing or receiving anythingof value (money, goods, services, etc.), or promising or proposing to do so, in orderto gain business or obtain inappropriate benefit. Business Partners should clarify andmonitor policies and procedures in order to comply with laws and regulations regarding
the prevention of corruption.

(5-3) Disclosure of Information
Disclose information regarding labor, health and safety, environmental
activities, business activities, organizational structure, financial situation,and performance according to local laws and regulations and prevailingindustry practices. Do not permit the falsification of records or the disclosureof false information.
Business Partners should actively provide and disclose information to stakeholders. The
information to be provided and disclosed to stakeholders includes the details of businessactivities, the company’s financial situation and performance, ESG (environmental, social,and governance) information, information on risks and incidents (such as damage due tolarge-scale disasters, adverse impacts on the environment and society, and the discovery
of significant legal violations), and information regarding the supply chain. Disclosing
information on critical risks in a timely manner and communicating to customers are also
examples of actively providing information. Business Partners are not permitted to tamper
with records, misrepresent information, or disclose false information. Business Partners
are expected not only to disclose information as provided for by laws and regulations,etc. but also to disclose information regarding efforts to stakeholders and customers withrespect to the Guidelines. Sustainability reports disclosed via corporate websites or inprinted media represent one example of such information disclosure.
15(5-4) Protecting and Respecting Intellectual Property
Do not infringe on the intellectual property of third parties when engaging inbusiness activities, including the development, production, and sale of products
and services. Protect your intellectual property and respect the intellectual
property of customers and third parties such as suppliers and contractors.
Intellectual property rights are rights defined by laws and regulations, and include patentrights, utility model rights, design rights, trademark rights, and copyrights. Intellectual
property includes trade secrets and technical know-how in addition to intellectual
property rights.

(5-5) Fair Business Activities
Promote fair business activities without engaging in unfair competition andacts that impede free competition, or advertising that involves misleading
content or rights infringements. Do not have any links whatsoever with any
antisocial groups that pose a threat to the order and safety of civil society andcomply with laws and regulations, ordinances, and all other social norms.
Business Partners should comply with laws and regulations regarding fair businesspractices, such as anti-monopoly and subcontracting laws, and must not engage inillegal acts such as cartel agreements to restrict competition, unfair business practices,or misleading representations. Also, Business Partners or their members of the board or
anyone who substantially controls the business shall not be a force that threatens theorder and safety of civil society (antisocial groups, etc.). Moreover, when it is found that
suppliers or contractors are antisocial groups or that they have links with such groups,
it is necessary that Business Partners avoid all links in an immediate manner. In catalog
presentations and the advertising of products and services, Business Partners should not
express untruths or mislead consumers and customers, and should also make sure not toinclude information that slanders or infringes the rights of other companies or individuals.

(5-6) Protecting Whistleblowers
In grievance mechanisms available to stakeholders, including workers ofyour company and your suppliers and contractors, ensure the confidentialityof what was reported and the anonymity of the whistleblower, etc.,
and protect whistleblowers from acts of retaliation and any otherdisadvantageous treatment by your company or individuals due to the act ofwhistleblowing.
Disadvantageous treatment refers to acts that harm the work environment such as
harassment, and changes to working conditions such as unfair performance evaluation,
rewards, dismissal, or reassignment.

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(5-7) Responsible Minerals Procurement
Check that manufactured products do not contain minerals that are linked togroups or forces that cause or are complicit in causing serious human rights
abuses, environmental destruction, corruption, or conflict, etc. in conflict
affected and high-risk areas.
The ideal means of checking for such minerals is through due diligence on responsible
minerals procurement. This refers to establishing policies, communicating expectations to
suppliers (and incorporating them in contracts where possible), identifying and reviewing
risks in the supply chain, and establishing and implementing strategies to handle theidentified risks. The OECD has issued an internationally-recognized document regarding
due diligence concerning responsible minerals procurement, entitled the Due Diligence
Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk
Areas.ⅶ

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6. Quality and Safety
Business Partners should ensure the safety and quality of their products andservices and provide accurate information on their products and services.

(6-1) Product Safety
Fulfill responsibility as suppliers by ensuring that products meet safety
standards provided for in local laws and regulations, and by engaging in
product design, manufacturing, and sales activities that ensure adequate
product safety.
When designing products, Business Partners should ensure adequate product safety
and consider their responsibility as a manufacturer when manufacturing and providing
products. Business Partners should also consider the safety that the product should
ordinarily provide, in addition to legal compliance. In Japan, safety standards relating
to product safety are defined in detailed regulations in domestic laws and in JapaneseIndustrial Standards (JIS). Overseas safety standards include UL, BSI, and CSA standards,
etc. Effective measures for ensuring product safety include management of areas such as
traceability (history of materials, components, and processes, etc.) and swift handling tosolve problems.

(6-2) Quality Management
Comply with your company’s quality standards and the TOPPAN Groupquality requirements, in addition to complying with local laws andregulations regarding the quality of products and services.
Business Partners should establish appropriate frameworks and management systems forcomplying with their own quality standards and the TOPPAN Group quality requirements,
in addition to complying with local laws and regulations regarding the quality of products
and services.

(6-3) Providing Accurate Information on Products and Services
Provide accurate information on products and services that will not cause
misunderstandings.
Business Partners should provide information to customers and consumers that isaccurate and does not cause misunderstandings. Business Partners must not provide false
information or information that has been falsified.

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7. Information Security
Business Partners should establish measures and systems to deal with computer
network threats, manage and protect data to prevent leaks of confidential
information and personal information, and enhance information security.

(7-1) Defense from Cyber Attacks
Establish and manage measures and systems to deal with computer network
threats so as not to cause damage to your company or others.
Business Partners should prevent trouble caused by cyberattacks, such as information
leaks or manipulation and the stopping of information systems. Since attackers can
expand their target of attack based on the customer and client information they obtain,
the scope of damage from cyberattacks is not limited to your company. Devices subject
to cyberattacks are expanding from conventional computers and servers to industrial
systems and IoT (Internet of Things) devices. Countermeasures should therefore be
implemented for such systems and devices. Business Partners are expected to establish aplan for prompt recovery if they become the subject of a cyberattack. Measures should
include, for example, setting complicated passwords, updating OS (Operating System:
basic system) and firmware, applying patches, backing up critical data, duplicating servers
and data centers, and maintaining a response mechanism in preparation for incidents.

(7-2) Protecting Personal Information
Comply with local laws and regulations and appropriately manage andprotect all personal information of customers, consumers, suppliers,
contractors, and workers, etc.
Business Partners should comply with local laws and regulations and carefully handle all
personal information of customers, consumers, suppliers, contractors, and workers, etc.
Business Partners should only collect, store, modify, transfer, share and otherwise process
personal information to the extent necessary to achieve the specified purpose of use.
Appropriate management refers to establishing and operating a general management
framework for personal information, and includes establishing rules and policies thatworkers must comply with, as well as establishing plans, implementing measures, andconducting audits and reviews in accordance with them. Appropriate protection refers
to preventing personal information from being unlawfully or unfairly obtained, used,disclosed, or leaked.

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(7-3) Preventing the Leak of Confidential Information
Appropriately manage and protect not only your own company’s
confidential information but also confidential information received from
customers and third parties.
Business Partners should establish an appropriate framework and management system for
managing confidential information. This includes establishing information managementlevels and worker education and training. Confidential information generally refers to
information disclosed according to a written confidentiality agreement or information
disclosed orally after notifying that it is confidential. Appropriate management refers
to establishing and implementing a general management framework for confidential
information, and includes establishing rules and policies that workers must comply with,
as well as establishing plans, implementing measures, and conducting audits and reviewsin accordance with them. Appropriate protection refers to preventing confidential
information from being unlawfully or unfairly obtained, used, disclosed, or leaked.

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8. Business Continuity Planning
Business Partners should make preparations to ensure that they can quickly resume
production activities, in order to fulfill their supply responsibilities, when thecompany, a supplier, or a contractor is affected by a disaster such as a large-scale
natural disaster.

(8-1) Developing and Preparing a Business Continuity Plan
Analyze risks that impede business continuity and strive to formulate a
Business Continuity Plan (BCP) that includes a detailed examination of the
impact on the business, preparatory countermeasures, and the status of theinitiatives.
A business continuity plan (BCP) is a plan created in advance that enables production
activities to be swiftly resumed so that a company can fulfill its supply responsibilities
when Business Partners or their business partners are affected by a disaster such as alarge-scale natural disaster. Risks that impede business continuity include large-scale
natural disasters (such as earthquakes, tsunamis, floods, heavy rainfall, heavy snowfall,
and tornadoes) and subsequent power outages, water stoppages, and transportation
impediments, accidents (such as fires or explosions), the spread of infectious andcontagious diseases, and terrorism or riots. Preparatory countermeasures include local
recovery strategies that indicate how to protect, mitigate, and recover various elements
at individual production sites from anticipated damage. Business Partners are expected to
strive to secure alternative methods that envisage recovery from damage taking longer
than expected. Business Partners are expected to establish a manual for quickly recoveringbusiness in accordance with the details stated in the BCP when business actually stops
and to provide continuous education and training to employees so that they can respondto actual disasters, etc.

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9. Establishing a Management System
Business Partners should strive to establish a management system to ensure propercompliance with the Guidelines.

(9-1) Establishing a Management System
Strive to establish a management system to ensure proper compliance with
the Guidelines. The purpose of the management system is to ensure:a. Compliance with local laws and regulations, and customer requirements
regarding business and products
b. Management of compliance with the Guidelines
c. Identification and management of related operational risks and promotionof continuous improvements
A management system refers to establishing a framework for continuous improvements
through the Plan-Do-Check-Action (PDCA) cycle regarding policy compliance,
implementation systems, corrective actions, and stakeholder engagement. Specifically,
it includes corporate commitment, management accountability and responsibility,
legal requirements and customer requirements, risk identification and management,
improvement goals, education and training, communication, worker feedback,participation, grievance filing, assessment and audit of identified risks, corrective action
processes, documentation and records.
In addition to management systems such as ISO in areas such as health and safety,
quality, and environment, there is the OECD Due Diligence Guidance for Responsible
Business Conduct,ⅷ which is a set of due diligence guidelines regarding all corporate
conduct. The guidance indicates the following six items as part of the due diligenceprocess.
(1) Embed responsible business conduct into policies and management systems(2) Identify and assess actual and potential adverse impacts associated with theenterprise’s operations, products or services(3) Cease, prevent and mitigate adverse impacts(4) Track implementation and results(5) Communicate how impacts are addressed(6) Provide for or cooperate in remediation when appropriate
Due diligence is the process that business enterprises should carry out to identify, prevent,mitigate and account for how they address actual and potential adverse impacts in theirown operations, their supply chain, and other business relationships.

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(9-2) Management of Suppliers and Contractors
Communicate the requirements in the Guidelines or similar guidelines
your company has established to your suppliers and contractors. Strive toestablish processes for monitoring compliance with the requirements bysuppliers and contractors.
According to the United Nations Guiding Principles for Business and Human Rights andthe OECD Due Diligence Guidance for Responsible Business Conduct, companies are
required to assume the responsibility for sustainability in their supply chain as well as intheir own companies. Therefore, Business Partners should communicate the requirementsin the Guidelines to suppliers and contractors, monitor the state of compliance, andpromote improvements.

(9-3) Proper Import and Export Controls
Maintain a clear management system and conduct appropriate proceduresfor the import and export of technologies and goods regulated by local laws
and regulations.
Business Partners should understand and comply with various national laws andregulations concerning importing and exporting. Technologies and goods regulated
by laws and regulations refer to components, products, technologies, equipment,
and software subject to import and export controls in laws and regulations based oninternational agreements, etc. (such as the Wassenaar Arrangement). Business Partners
should obtain any necessary permission from the competent authorities regarding
importing and exporting.

(9-4) Establishing Grievance Mechanisms
Establish and communicate grievance mechanisms that can be used bystakeholders, including workers, suppliers, and contractors, in order toprevent the violation of the Guidelines within your company and in yoursupply chain.
In order to comply with the Guidelines, in addition to due diligence, Business Partners
should establish grievance mechanisms for receiving reports from stakeholders, including
workers, suppliers, and contractors, and facilitating responses and corrective action,and should enable a continuous process of addressing issues at stake. If it is difficultfor Business Partners to establish such mechanisms by themselves, they can participate
in grievance mechanisms operated by industry groups in which multiple companies
can participate. In order for a grievance mechanism to function effectively, it is useful
to take measures to facilitate understanding among stakeholders who are potential
whistleblowers, to conduct awareness surveys to check the level of understanding, andto ensure stakeholders' participation in continuous improvements based on advice from
related parties and experts. Business Partners should enable complaints to be lodged
anonymously. Whistleblowers must not be subject to acts of retaliation or any otherdisadvantageous treatment due to making complaints.

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Revision History
Date Revised

VersionMain Revisions

May 2007

Version 1

Established the Toppan Group CSR Procurement Guidelines

January 2014

Version 2

Organized CSR Procurement Standards into Basic Procurement Standards and Procurement
Standards for Human Rights, Labor, Environment, and Anti-Corruption

January 2022

Version 3

Changed name to the Toppan Group Sustainable Procurement Guidelines
Organized Sustainable Procurement Guidelines into nine sections, Legal Compliance andRespect for Internationally Recognized Standards, Human Rights and Labor, Health and Safety,
Environment, Fair Business and Ethics, Quality and Safety, Information Security, BusinessContinuity Planning, and Establishing a Management System

October 2023

Version 3.1

Changed name to the TOPPAN Group Sustainable Procurement Guidelinesⅰ		UN’s Guiding Principles on Business and Human Rights: Implementing the United Nations “Protect, Respect 		
and Remedy” Framework, United Nations, 2011,(https://www.ohchr.org/documents/publications/guidingprinciplesbusinesshr_en.pdf, accessed on January 18, 				2022)ⅱ
United Nations, Transforming Our World: The 2030 Agenda for Sustainable Development, United Nations, 		2015 (https://sdgs.un.org/2030agenda, accessed on January 18, 2022)
ⅲ
OECD Guidelines for Multinational Enterprises, 2011 Edition, OECD, 2011,
		(https://www.oecd-ilibrary.org/governance/oecd-guidelines-for-multinational-enterprises_9789264115415-en, 		
accessed on January 18, 2022)
ⅳ
ILO, Tripartite Declaration of Principles Concerning Multinational Enterprises and Social Policy (MNE 			
Declaration), Fifth Edition, ILO, 2017,(https://www.ilo.org/wcmsp5/groups/public/---ed_emp/---emp_ent/---multi/documents/publication/			
wcms_094386.pdf, accessed on January 18, 2022)ⅴ
United Nations Global Compact, Business Reference Guide to the UN Declaration on the Rights of Indigenous 		
Peoples, United Nations Global Compact, 2013 (https://d306pr3pise04h.cloudfront.net/docs/issues_			
doc%2Fhuman_rights%2FIndigenousPeoples%2FBusinessGuide.pdf, accessed on September 24, 2021)
ⅵ
METI Guidebook on Chemical Risk Assessment for Business Operators, Ministry of Economy, Trade and Industryof Japan, 2007, (https://www.meti.go.jp/policy/chemical_management/law/prtr/pdf/guidebook_jissen.pdf, 		
accessed on September 21, 2021)
ⅶ
OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk
Areas, Third Edition, OECD, 2016, (https://www.oecd.org/daf/inv/mne/OECD-Due-Diligence-Guidance-MineralsEdition3.pdf, accessed on January 18, 2022)
ⅷ
OECD Due Diligence Guidance for Responsible Business Conduct, OECD, 2018 (https://mneguidelines.oecd.org/
OECD-Due-Diligence-Guidance-for-Responsible-Business-Conduct.pdf, accessed on January 18, 2022)24