Good governanceAll the JT Group operations are required to comply with the high standards of business integrity laid
down in the JT Group Code of Conduct. These include preventing bribery and corruption, avoiding
discrimination, respecting human rights, environmental protection, data privacy, and faircompetition.

GovernanceOur policies

Compliance

Tax practices

Risk management

Information security

Transparency andstakeholder
engagement

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Group compliance
Our responsibilities to stakeholders
Compliance is the foundation that will allow us to achieve sustainable profit growth over the mid tolong term under the 4S model, our management principle. We define the JT Group Compliance as“Actions for the shared JT Group Purpose, based on the values and ethics we must hold in order tobecome better corporate employees and citizens”.

Our compliance system
Our compliance system plays a significant
role in the JT Group governance and ensuresthat all employees comply with ourcompliance standards.
Read more

Our Codes of Conduct
JT Group's compliance is upheld by ourCodes of Conduct, communication channels
for reporting concerns, and various
compliance programs.
Read moreCompliance risk management
The JT Group makes the utmost effort toensure all of our business operations arecarried out in an appropriate way and gain ahigh level of trust and confidence from ourstakeholders by reinforcing compliance risk
management.
Read more

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Our compliance system
The JT Group Compliance Committee plays a significant role in the JT Group governance. Its aim isto ensure that all directors and employees fully comply with applicable laws, our Articles ofIncorporation, cultural expectations, and other compliance standards. The roles of the Compliance
Committee are as follows:■

Hold meetings where compliance-related matters are reviewed and discussed to report directly
to the Board of Directors■

Discuss the Annual Compliance Program and Annual Compliance Action Plans■

Instruct on investigation of any suspected serious compliance violation case and correct andprevent recurrence if any violation is detected

The head of the JT Group Compliance Committee is the Chairman of the Board, and the Committee
includes external experts as key members. The Committee meets regularly three times every year.
Among the matters discussed are initiatives to promote compliance throughout the Group, andthese initiatives are executed based on the Annual Compliance Action Plan. The Action Plan
includes maintaining and enhancing the compliance system, taking action on Company priority
issues, carrying out training and seminars, handling the Reporting Concerns Mechanism, andimplementing the Compliance Promotion Month. The Compliance Promotion Month takes place inJune every year. The aim is to raise employees’ awareness of this important subject, throughinformation sessions in every workplace, e-learning, and seminars for managers in ourheadquarters.
The Legal and Compliance division oversees departments to ensure that compliance is functioning
appropriately. It also promotes compliance by running various training programs for executives andemployees. Employees can report any violations or consult about possible violations of the JT
Group Code of Conduct by calling internal or external hotlines. The Legal and Compliance division is
responsible for investigating reported cases, and in the case of proven violations, each work divisionmust implement corrective measures. Serious cases are reviewed by the JT Group Compliance
Committee, and reported to the Board of Directors as necessary.
Similarly, in our tobacco business* we have our own Compliance department led by the JTI Chief
Compliance Officer. JTI Compliance department supports employees with various complianceprograms and training courses to guide them to act with integrity and make decisions in compliancewith all applicable laws and internal policies, and to mitigate reputational, legal and financial risks
for our international business.
* Tobacco business excluding Japan market

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Copyright© Japan Tobacco Inc. All rights reserved.

Our Codes of Conduct
The JT Group has established the ''JT Group Compliance Policy,'' which summarizes the JT Group's
values and ethics that are common globally, to practice compliance. In addition, we have tailored theCodes of Conduct to the unique environments and characteristics of each corporate and business
unit, which serve as the basis for our employees' daily actions. Our Reporting Concerns Mechanism
allows employees and business partners to report concerns in a confidential manner. We take azero-tolerance approach to bribery, corruption, and other financial crime, and we actively manage
risks related to these areas.
We train employees on the codes, and there are communication channels for employees to reportconcerns about potential breaches or violations.
JT Group Compliance Policy
JT Group Code of Conduct (Tobacco Business in Japan)
JT Group Code of Conduct (Pharmaceutical Business)
JT Group Code of Conduct (Processed Food Business)
JT Group Code of Conduct (Corporate)
JTI Code of Conduct
JT Group Supplier Standards

Living our Codes of Conduct
Our employees sign an acknowledgment form to show their commitment to following our Codes ofConduct. In the biannual performance appraisal of employees at JT, confirmation of compliancewith our Codes of Conduct is integrated into the process.
Our Codes of Conduct are reviewed every few years and revised when necessary, considering theenvironments in which we operate. We revised and updated the Codes of Conduct in 2012, 2015,
and 2018. In 2021, we reviewed the codes in their entirety and evaluated the need for revision. As aresult, after consulting with relevant divisions, we determined they were sufficient at that time, andleft them unchanged. In 2024, we established the ''JT Group Compliance Policy,'' which summarizes
the JT Group's values and ethics that are common globally, to practice compliance. In addition, we
have tailored the Codes of Conduct to the unique environments and characteristics of eachcorporate and business unit, which serve as the basis for our employees' daily actions. In the future,
we will continue to review the codes periodically and revise them when necessary. In our tobacco

business*, the JTI Code of Conduct has been digitalized into an accessible, easy-to-read document,
including a decision-making guide to assist employees in making the right choices. It is available in
42 languages.
* Tobacco business excluding Japan market

Training and communication
We continued to provide training on the Codes of Conduct to our employees in 2023. We provide
training programs to all employees, regardless of their employment status (e.g., directly or indirectly
employed, full or part time).
In our Japanese operations, 99.2% of employees completed the online courses.
To ensure that the JTI Code of Conduct is communicated effectively throughout the entire tobacco
business*, we run various communication campaigns, initiatives and training courses for all
employees. We also use an interactive Code of Conduct video in multiple languages to guide our
employees to make the right choices.
* Tobacco business excluding Japan market

Compliance survey in Japan
In order to better implement compliance in our workplaces, each department in our Japanese
operations makes Compliance Action Plans. These action plans are rolled out on a yearly basis,
which means they are based on the results of the compliance survey and the status of our initiatives
in the previous year.
We conduct a compliance survey every year. In 2023, 96.7% of employees completed the survey.
Survey results are analyzed by JT's Legal and Compliance Division, and reported to the head of eachdepartment while ensuring confidentiality. Next, JT's Legal and Compliance Division develops an
Annual Compliance Action Plan based on the results of the analysis. The relevant departments thenintroduce remediation plans to address any issues raised, using quantitative targets to evaluate theeffectiveness of the plan.

Based on the survey results and compliancerelated matters in 2023, we set priority
issues in 2024 which are deemed necessaryfor each division, such as preventing
harassment*. We will provide training
programs incorporating these issues during
Compliance Promotion Month in June andstrengthen and implement necessary
measures with related departments.

* Harassment includes sexual harassment andbullying.

Reporting concerns
Across the JT Group, each of our operatingcompanies has specially trained members
who handle compliance matters. If an
employee is concerned about a potential
violation of our Codes of Conduct, they cancontact their line manager, their HR lead, or a

* In our Japanese operations, we distribute aReporting Concerns Booklet to all employees withdetailed information about the process for reporting
concerns.

member of the compliance team. We also
provide an external concern-reporting
service, run by an independent provider andavailable 24/7. In addition, the Audit &Supervisory Board members in our Japanese
operations have established a consultation
and reporting contact independent ofbusiness operations. Every reported concern
and investigation report is treated on astrictly confidential basis, and retaliation
against anyone reporting a concern will not
be tolerated. Employees can file a reportanonymously if they prefer. Our approach is
explicitly described in our internal policy andemployee handbook so that our employees
can be aware of their rights and free of fear.
JT reporting concerns (for business
partners)
JT reporting concerns*
JTI reporting concerns

We believe that everyone should be able to raise concerns and have their voice heard, even if they do
not have access to a company computer and/or the company network. That's why we ensure secureaccess to the reporting system for all of our employees, at all times and from anywhere.
We offer multiple communication channels for employees, customers, and business partners to
confidentially raise concerns about potential violations of our Codes of Conduct or policies. We
review all concerns raised, launch investigations as needed, and take appropriate corrective actions.
Employees are informed of our Reporting Concerns Mechanism through various channels, including
the JT Group intranet. In our Japanese operations, the mechanism is available in five languages(Japanese, English, Chinese, Vietnamese, and Nepalese) to meet the needs of our diverse
workforce.
Any concerns are then dealt with by specially trained contact persons, who all follow a mandatory
training course.
In our tobacco business*, we are committed to achieving and maintaining the highest standards of
ethical behavior and acting responsibly in all we do. JTI Reporting Concerns Mechanism, called

''Your Voice'', helps meet these standards by allowing employees and business partners to
confidentially report behavior related to our business, which they believe is in breach of the JTI Codeof Conduct, JTI policies and procedures, or applicable laws.
We believe that everyone should be able to raise concerns in relation to our business and have their
voice heard. We ensure secured access to the Your Voice for all of our employees and business
partners, either via a portal run by an independent provider, accessible 24/7 in more than 70
countries and 50 languages with a computer or phone, or via a dedicated email address.
Every reported concern and investigation report is treated confidentially. All substantiated instancesof misconduct are addressed appropriately, and retaliation against anyone reporting a concern is
not tolerated.
Examples of the types of issues that can be reported through our Reporting Concerns Mechanism
are: human rights concerns, fraud, theft, corruption, money laundering, illicit trade, discrimination,
moral and sexual harassment, or other forms of inappropriate behavior.
In 2022, we received 631 reports across the JT Group. In a total of 361 cases, violations of ourCodes of Conduct we discovered, and we implemented remedial action in the form of dismissal,
verbal or written warnings, financial penalties, or other measures. For instance, we took remedialaction in 169 cases concerning fraud and misuse of company assets and 88 cases concerning labor
practices (excluding human rights). More specifically, we took remedial action in 2 cases concerning
corruption, 1 case concerning data privacy violation, 8 cases concerning conflicts of interest, and 1
case concerning discrimination. Regarding money laundering and insider trading, there were no
substantiated cases, thus no remedial action was taken.
* Tobacco business excluding Japan market

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responsibilities
to stakeholders

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Compliance risk
management

Copyright© Japan Tobacco Inc. All rights reserved.

Compliance risk
management
We make every effort to ensure that all of our business operations are carried out in an appropriate
way, and that we focus on compliance risk management to maintain our stakeholders' trust.
In our Japanese market in the tobacco, pharmaceutical, and processed food businesses, every
division is required to assess their compliance risks and submit action plans to address any risks
identified. A compliance survey is conducted every year and each organization incorporates theresults into their action plan.

Anti-bribery and corruption
With operations spanning the world, some ofour businesses are conducted injurisdictions with a high prevalence ofbribery and corruption. Our Codes ofConduct clearly prohibit bribery and forbid
corrupt practices in any form. Taking into
account legislation such as the Unfair
Competition Prevention Act of Japan, U.S.
Foreign Corrupt Practices Act, U.K. Bribery
Act, and anti-bribery laws in China, we haveintroduced the JT Group Anti-Bribery Policy.

We take a zero-tolerance approach to bribery, corruption, and other financial crime, and actively
manage risks related to these areas.
In Japan, we run an e-learning course on anti-bribery and corruption periodically. Through thisprogram, we aim to gain a better understanding of corruption with a view to preventing it at the JT
Group and reducing the risk of becoming involved in corruption cases. The course focuses on
business dealings with government bodies, etc. that use agents and where the risk is particularlyhigh. The participation rate for the e-learning course in 2023 was 99.2%.
In our tobacco business**, we take a zero-tolerance approach to bribery, corruption, and otherfinancial crime, and we actively manage risks related to these areas.
In 2022, as part of our annual focus on training, we provided training through Introduction toCompliance to 2,072 new employees, and anti-bribery and corruption training to 5,866 employees(new employees hired in 2022 and re-enrolled employees from previous years).
To mitigate the risks of bribery and corruption, we have also updated several corporate compliance
procedures, including Employee Disclosure and Declarations, Know Your Business Partner, andPreventing Financial Crime.
** Tobacco business excluding Japan market

JT Group Code of Conduct (Tobacco Business in Japan)
JT Group Code of Conduct (Pharmaceutical Business)
JT Group Code of Conduct (Processed Food Business)
JT Group Code of Conduct (Corporate)
JTI Code of Conduct
JT Group Anti-Bribery Policy

Gifts, hospitality, and entertainment
We do not encourage the exchange of gifts, hospitality, or entertainment (GHE), but we recognizethat occasional GHE is a common business practice. We must always be transparent when
exchanging GHE, as such action could otherwise be interpreted as a bribe or conflict of interest.
To mitigate and prevent such risks, we have established internal GHE policies and procedures.
These help to prevent bribery and conflicts of interest. They also help to ensure an appropriate levelof GHE exchange, which must be transparent and reasonable, and must respect local regulations.
Where our standards are stricter than local laws, we require our local offices to comply with ourstandards.
We provide regular training and run communication campaigns to ensure that compliance is wellembedded within our organization.

Anti-competitive behavior

Compliance with competition laws is covered by our Codes of Conduct, which require employees tocompete fairly in all markets.
In our tobacco business*, we have a policy with detailed guidelines in place to ensure that ourbusiness is conducted fairly and in compliance with competition laws at all times. The policy
requires our employees to conduct business in an ethical manner and in compliance withcompetition laws. For example, all personnel are required to determine JTI's commercial strategies
and make decisions independently from our competitors and in the interest of JTI alone, without
consultation, influence by, or access to competitors' competitively sensitive information.
In addition, we do not enter into agreements with competitors or third parties operating at different
levels within the supply chain (e.g., trade customers, such as distributors or retailers) that have as
their aim or effect the prevention, restriction or distortion of competition. Our customers must be
free to make their own business decisions concerning their customers and how they compete in themarket.
We have developed extensive training materials. Our employees are required to attend regulartraining sessions on compliance with competition laws and our policy.
* Tobacco business excluding Japan market

Preventing financial crime
We do not tolerate any form of financial crime. We perform policy controls and provide training
programs to our employees. We also publish communications on the subject regularly. Our global
policy sets out principles and guidelines to prevent employees from being involved in any form offinancial crime, including money laundering, tax evasion, and facilitating tax evasion.

Tax compliance
The JT Group Tax Policy outlines our approach to tax compliance, tax risk management, theutilization of external tax advisors, and our relationship with tax authorities. Read more on tax
practices.
The JT Group Tax Policy
Tax practices

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Our policies
Our management approach is underpinned by our 4S model. Consumers, shareholders, employees,
and society represent the four stakeholder groups (4S) at the heart of everything we do. The policies
and principles below define our commitment to these four stakeholder groups.

Governance and compliance
The JT Corporate Governance Policy
The JT Group Code of Conduct

Human rights
The JT Group Human Rights Policy

Environment
The JT Group Environment Policy

Community investment
The JT Group community investment policy

Supply chain
The JT Group Responsible Procurement Policy
The JT Group Supplier Standards
The JT Group Principles in Leaf Tobacco Production

Tobacco businessOur tobacco principles
Our global tobacco marketing principles

Related links
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Tax practices

Risk

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management

security

Transparency
and stakeholder
engagement
Copyright© Japan Tobacco Inc. All rights reserved.

Tax practices
The JT Group is committed to being a
responsible corporate citizen across allareas of our operations, and in all countries
in which we source, manufacture, or sell our
products. This is an essential component of
how we work as a business and who we are
as a company.
This global commitment is driven by amanagement philosophy that puts key
stakeholder groups at the heart of oureveryday decisions and actions. Our 4S
model ensures that we strive to fulfill our
responsibilities to our valued consumers,
shareholders, employees and the wider
society, carefully considering the respective
interests of these four key stakeholder
groups, and exceeding their expectations
wherever we can. Effective compliance,
audit and risk management play importantroles in how we conduct ourselves,
everywhere.

This is particularly true in the increasingly complex area of taxation. Our tax commitment is
unequivocal: “We are fully committed to paying our fair share of taxes within both the letter and thespirit of the law.” In doing so, we aim for our tax affairs to be transparent and sustainable in the longterm, and we do not engage in aggressive tax planning, or tax avoidance schemes. We neither use
legal entities, secrecy jurisdictions, or tax havens, purely for tax purposes, nor will we undertake tax
planning for tax avoidance reasons or without commercial justification. We undertake to meet alllegal requirements and make all appropriate returns and payments on time. We communicate
closely and transparently with tax authorities to enhance their understanding of our business.
In areas of uncertainty, we seek to discuss our interpretation of tax rules with tax authorities and,
where appropriate, obtain tax rulings. Where disputes arise with tax authorities with regard to theinterpretation and application of legislation, we are committed to addressing the issues promptly
and resolving them in an open and constructive manner.

Our Group Tax Policy
The JT Group Tax Policy (hereinafter, the “Policy”) outlines the framework for ensuring appropriate
conduct of tax affairs to enhance the corporate value through our “4S” model. This policy provides
general guidance in respect of tax compliance, tax management and the use and engagement of
external tax advisors, and relationships with tax authorities and business partners within the JT
Group. This policy is approved by the JT Group CEO.

Basic PolicyA）Tax Compliance
JT Group will:■

Comply within both the letter and spirit of local laws and regulations in every country and regionin which JT Group conducts business■

Use the arm's length principle for all transfer pricing■

Submit tax returns accurately and in time■

Make tax payment when due■

Retain adequate documentation supporting its tax filings and payments■

Comply with IFRS and / or local GAAP accounting as appropriate to their business, in respect of
Taxes

■

Comply with Operating Guidelines related to the Policy■

Report to JT management on regular basis in order to confirm complianceB）Tax Risk Management
JT Group will:■

Seek a consistent and balanced approach regarding Tax Risk Management■

Demonstrate the highest level of integrity and abide by the highest standards and comply withlaws, regulations and other rules

JT Group will not:■Use an entity only for tax purposes■

Use secrecy jurisdictions or tax havens only for tax purpose■

Undertake tax planning for tax avoidance reasons or without commercial justification.

C）Utilization of External Tax Advisers
JT Group establishes and maintains relationships with External Tax Advisers for the followings:■

Achieve the highest quality of Tax Compliance and Tax Risk Management■

Ensure efficient and effective utilization of External Tax Advisers■

Ensure the highest standards of service at the lowest cost level■

Reduce the reliance on External Tax Advisers in order to develop the internal capabilities within
the JT Group■

Where necessary for attorney/ client legal privilege, ensure consideration is given to use of alegal firm as External Tax Advisers

D）Relationship with tax authority
JT Group will:■

Maintain the appropriate level of relationship with tax authorities to ensure a high standard ofcorporate reputation■

Maintain a proactive, open and transparent communication with tax authorities in order toenhance their understanding of the JT Group business and resolve matters in a constructive
manner where disputes arise with regard to the interpretation and application of tax legislation

Our tax control framework

Our objective is to manage tax risk and pay what is rightly due.
The main areas of tax risks we identified relate to tax law changes, compliance and reporting:■Tax law changes: exposure driven by tax law changes enacted unexpectedly, retroactive
legislation, changes in interpretation or application of tax laws by authorities.

■

Compliance: non-compliance with global or local tax laws and regulations, including wrong
application of tax regulations, errors / delays in tax filings, documentation and reporting,incorrect interpretation of transfer pricing guidelines and/or taxation laws by JTI employees,
advisers or regulatory bodies.

■

Reporting: inability to estimate existing or future tax obligations and record appropriate
provisions.

All risk areas are monitored and managed closely via our tax control framework:
Tax affairs within the JT Group are managed by our experienced in-house tax team, who are actively
involved in all major commercial and operational transactions. To control the tax risks JT Group’s
tax team uses external consultants; conducts tax health checks; keeps up to date via tax literature,newsletters, external training, and membership of tax professional organizations; and mandatorily
and regularly applies web-based tools to capture changes in existing and new tax positions andcompliance status.
Significant tax positions, and the risks arising from these - together with potential mitigating actions- are considered by the relevant level of management when strategic decisions impacting eachcompany are taken. We also seek advice from external professional advisers or look for prealignment with tax authorities for material transactions where appropriate, to minimize potential
risk.
The allocation of responsibility is clearly set out in the JT Group Operating Guidelines and the JT
Group Tax Policy. Material transactions and issues are considered by relevant boards. There is aregular review of material transactions and tax positions by senior management. Adherence to ouroperating guidelines in respect of authorization and approval levels for all transactions andcompliance tax matters is mandatory.
The JT Group Tax Policy is reviewed and approved by the JT Group CEO. The tax strategy of each
entity is reviewed regularly. The responsibility for this - as well as management of tax risks, rests
with the Chief Financial Officer of each entity, together with the Global Tax Vice President.

Our effective tax rate

The effective statutory tax rate in Japan is 30.43% (FY22). However, as we, as a Japanesemultinational, also have operations outside Japan, the profits we generate cannot be taxed in Japan
only. In order to come to a logical effective tax rate, we use a blended rate representing a blend of
the local statutory rates applicable for each market, of which most have a lower tax rate than theeffective statutory tax rate in Japan. As mentioned in our Group Tax Policy, we use internationaltransfer pricing standards to safeguards that all markets have the opportunity to levy tax upon the
profits allocable to their markets and get their fair share of taxes.
The amount of corporate income taxes, including deferred income taxes, amounted to 149,277
million yen, which represents the effective tax rate of 25.15% in 2022. Adjustments will be seen as
the reported profits will not fully align with the taxable profits in the markets due to the applicabilityof local tax laws. The reconciliations between the effective statutory tax rate in Japan and thecalculated effective tax rate (ETR) for JT can be specified as follows:(%)

Effective statutory tax rate in Japan

30.43

Different tax rates applied to foreign subsidiaries(11.37)

Non-deductible expenses

2.72

Non-taxable incomes(1.12)

Valuation allowance

1.47

Tax credits(1.44)

Retained earnings

1.35

Withholding tax in foreign countries

1.16

Other

1.95

ETR in 2022

25.15

Our tax contribution
As one of the world’s largest tobaccocompanies, we make significant
contributions to government revenues
through taxation. In 2022, approximately
66% of 9,229,388 million yen gross revenue
flowed back into global society throughtobacco excise and corporate taxes. We
accrued 5,930,211 million yen in tobacco
excise taxes, amounting to 64% of global
revenues; and 176,545 million yen in current
income taxes (corporate tax), accounting fora further 2% of revenue. Besides this, we areresponsible for the collection and paymentof other taxes including employment taxes
and other indirect taxes. Collectively, we
believe these taxes paid contribute tofunding many essential services on whichcurrent and future generations may depend.

Tax has also been recognized as an important sustainability subject by the JT Group’s seniorleadership. This is reflected in the JT Group sustainability strategy.
To help the Group to grow, and to build a sustainable future as a member of the society in which we
operate, we have identified high-priority material issues. Tax practice is one of these topics. It is alsoa focus area of “Good governance and business standards”, one of our group’s sustainability
initiatives. Read more on “Materiality”.
The above tax statement is also published for and on behalf of all U.K. sub-groups and qualifying
U.K. entities in our Group, in accordance with the requirement to publish a tax strategy for eachfinancial year under section 161 and paragraph 19 of Schedule 19 to the Finance Act 2016 in
relation to the year ended 31 December 2021. The above references to tax authorities include the
U.K.’s HMRC. A link to the above information, which applies to all UK entities, is included in the
JTI UK website.

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Information security
Our information security risks relate to all the valuable data we hold. This not only includes details
about our customers, consumers, suppliers, and employees, but also information on our businessstrategy, our engineering and experimental data, including results from research. The danger is that
this important information could be stolen, leaked, or damaged in some way.
In order to minimize this risk, we are committed to continually enhancing our information security
framework. We understand the importance of awareness and the role every employee can play inkeeping our data safe. We ensure that our regularly updated policies and procedures are shared withand understood by employees, as education is a key component of our broader cyber defense
strategy.

IT risk management
The JT Group IT Governance Policy is top of our hierarchy of IT policies and procedures. This is the
bedrock of information security governance. We operate IT controls to support relevant legal andregulatory requirements, specifically how personal and financial information is controlled andprocessed. The Senior Vice President, Information Technology has managerial responsibility over
the JT Group’s IT Governance systems.

Personal information protection
To appropriately protect and ensure the responsible use of data, handling of personal information isconducted in accordance with appropriate laws and regulations specifically as it relates toapplicable data protection legislation. In addition, our internal policies set out the guidelines forcollecting, processing, and use of personal information. Through employee awareness andprotection technologies, labeling and classifying personal information has now become essential
elements in controlling, tracking and protecting information.

Monitoring system
Our IT infrastructure and information security management systems are continuously monitoring todetect cyber threats. Existing security detection systems are systematically assessed by internaland external auditors, ensuring our practices meet the highest standards. As part of our continual
improvement strategy to harden our security posture and adapt to an ever-changing threat

landscape, we instruct third-party providers to perform vulnerability testing. Simulated cyber-attacks
are a valuable part of our strategy to help us find areas of improvement, as well as simultaneously
testing our incident response procedures.

Business continuity and incident response
One of our key focus areas is ensuring continuity of critical business processes and reducing risk tofinancial and or reputational damage. In the event of a disruptive incident or cyber-attack, we have arobust response structure, which is based on the following aspects:■

Our IT Business Continuity Policy describes the efforts of our IT team to support businessprocess continuity. The most important of these processes are detailed below.

Critical IT infrastructure, such as our data centers, has recovery and rehearsal
Disaster recovery procedures

procedures in place to simulate disaster scenarios. This enables us toand plans

understand how well procedures are operating and identify any areas for
improvement.

IT service availability

IT controls are in place to ensure the availability of business-critical IT services
in worst case scenarios.

We have efficient data backup and restoration procedures to restore businessData backup and restoration

critical data within the required timelines. Controls are also in place to protect
confidential data and data integrity, in order to minimize business disruption.

Robust procedures and service-level agreements (SLAs) are in place in theevent of an incident. Clear investigation and incident post-mortem processes
Incident management

exist. These help us to understand the root cause of such incidents and prepare
for similar scenarios in the future. They also help us to avoid repeating the same
mistakes.

■

In our tobacco business, we have carried out a major cyber crisis preparedness audit. The
procedures and playbooks to deal with cyber events are in development. Once ready and tested,these will be shared within JT Group.

Information security training
Our information security awareness strategy empowers our employees to be the first line of defense
against cybercrime and attacks. It provides the tools and know how they need to identify threats andtake appropriate action to protect the JT Group.
JT Group implemented a global bespoke i-secure program, which was established to promote a
culture of cyber security awareness both at home and at work. The annual learning program is
executed in 100% of locations worldwide. 88% of employees in our all employees received
information security e-learning. Key behavior indicators allow us to constantly measure theeffectiveness of our program. This learning initiative supplements our technological defenses
against cybercrime, by ensuring that all employees understand how to better protect our
information. We also pay special attention to the cyber security risks around executives. In Jan 2023
we held a security briefing session (including threats and risks) for directors and non-executive
board members.

As we increasingly move towards the use of cloud services for data processing, we are re-evaluating
risks and strengthening our security defenses. We continually assess the threat to our company
using a variety of security intelligence methods. The JT Group's vision is to become the number one
leading tobacco company by 2030. This will require technological advances, which in turn bring new
and complex security challenges.
It is the role and responsibility of Information Security to constantly adapt to the ever-changing
technical landscape. We are making great efforts to continually improve the security of all areas of
the business, with a focus on global collaboration to ensure that the best security practice anddefense technologies are used across the JT Group.

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Transparency and stakeholder
engagement
We regularly engage with consumers, shareholders, employees, and members of wider society tounderstand the issues that matter to them most, and to meet their needs and expectations. This
engagement is vital in helping us to make decisions that will drive long-term sustainability. Listed
below are our key stakeholder groups and how we engage with them.

Customers and consumers■

Our sales force interacts with our retailers and consumers on a day-to-day basis to better
understand their needs and preferences (e.g. visiting retailers, interactive sampling of new
products where legally permitted, etc.)■

We respond to product and business enquiries from consumers through our consumer hotline
service■

When it comes to developing our RRP (Reduced-Risk Products), we listen to what our consumers(The word, consumers, used in the context of the tobacco business means adult consumers.
Minimum legal age for smoking varies in accordance with the legislation in each country.) wantto make sure that we provide them with the widest range of quality products

Read more about how we engage with our consumers through the hot-line service, or about our

products and services.

Shareholders■

We hold an annual general meeting every year and present our financial results to ourshareholders■

We are in regular contact with institutional shareholders to discuss the issues of concern tothem

Read more about how we engage with our shareholders.

Employees

■

We conduct regular employee engagement surveys to understand how we can continuously
improve employee satisfaction■

Our employees have regular opportunities to discuss their career aspirations throughperformance assessments■

Our Codes of Conduct are developed in collaboration with our employees, and concerns about
violations can be shared with management anonymously through our Reporting Concerns
Mechanism■

In our international tobacco business, our people celebrate their sustainability initiatives andshare new ideas through our annual Sustainability Awards

Read more about how we engage with our employees or about our reporting concern mechanism.

Suppliers■

All of our suppliers are required to comply with our JT Group Supplier Standards and we selectour suppliers not only based on quality, service, and cost, but also on their compliance with ESG
related standards such as ensuring the health and safety of their employees. This is reflected in
our JT Group Responsible Procurement Policy■

In our tobacco business, we support our growers through our Agricultural Labor Practices, whichallows us and our suppliers to identify potential labor challenges on tobacco farms and help
improve growers’ labor practices■

For our non-tobacco materials, we develop strong partnerships with our key suppliers in order toachieve mutual long-term success

Read more about how we engage with our suppliers.

Trade associations■

We engage with trade associations by participating in working groups and policy commissions inorder to achieve a better business environment not only for us but also for other member
companies

Communities■

We support the development of inclusive and sustainable societies by voluntarily engaging withcharitable organizations in the communities where we operate■

We provide post-disaster support to local communities

Read more about how we engage with the communities in which we operate.

Non-governmental, regional, and internationalorganizations■

We partner with non-governmental organizations and non-profit organizations to deliver ourcommunity investment programs■

We partner with organizations supporting the communities where we buy tobacco leaves

Read more about how we engage with the communities in which we operate, or with thetobacco leaf communities.

Governments and regulators■

We engage in open and transparent dialogues with governments and regulators regarding
regulations affecting our business and society■

While engaging with regulators, we strictly comply with our anti-bribery policy which isembedded in our Codes of Conduct■

We will enhance our cooperation with governments to combat illegal trade

Related links
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and stakeholder
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