JT Group Compliance Policy

1. Ensuring product quality
We manage world-class operations, which consistently meet JT Group quality standards andconsumer expectations.

2. Marketing our products responsibly
We are committed to marketing our products responsibly.

3. Respecting data protection & privacy
We ensure we collect, use, share and store personal data lawfully and securely. We apply the samecare to JT Group other information.

4. Managing external communications
Only authorized representatives may engage with journalists on behalf of JT Group.

5. Cooperating with government inquiries
We fully co-operate with government inquiries and investigations.

6. Reporting and recording Company data
Our business relies on true, fair, timely and accurate record-keeping and reporting to support ourdecision-making, protect our reputation, promote operational efficiency and meet legal andregulatory obligations.

7. Preventing insider dealing
Employees must not engage in insider dealing under any circumstances.

8. Safeguarding Company assets
We treat JT Group Company assets, and assets belonging to others, responsibly and with respect.
We ensure that our Company assets are correctly acquired, maintained, protected and disposedof.

9. Avoiding conflicts of interest
We expect employees to avoid any situation where their personal interests might conflict with thoseof JT Group.

10. Remaining politically neutral
It is in our best interest to remain politically neutral.

11. Treating people equally and with respect
We embrace diversity, equity, and inclusion. We promote a working environment where everyone
can be themselves without risk of discrimination or harassment.

12.Ensuring health and safety
All employees have the right to be protected from work-related injuries and illnesses. We providethem with a safe working environment and promote a culture that prioritizes health and safety.

13.Respecting human rights
Throughout our business operations, we commit to respect the human rights of our employees,
business partners and their workers, and the communities where we operate.

14. Fighting bribery and corruption
We have a zero-tolerance approach to bribery and corruption, and we are committed to acting withintegrity in all our business dealings.

15. Exchanging gifts, hospitality and entertainment
We do not encourage the exchange of gifts, hospitality and entertainment (GHE), but weacknowledge that appropriate GHEs, made for the right reason, are legitimate and are recognizedas part of doing business.

16. Combatting illegal trade
We combat illegal trade through our partnerships with law enforcement agencies and governments.

17. Preventing financial crime
We do not tolerate financial crime and are committed to actively managing risks related to it.

18. Respecting economic sanctions and export
controls
We are committed to complying with applicable economic sanctions and export controls.

19. Engaging with business partners
Our business partners are critical to our success. They are carefully selected based on criteria
including compliance with laws and regulations, business integrity, quality, health and safety,
human rights, labor standards and environmental management.

20. Ensuring fair competition
We firmly believe that free and fair competition benefits JT Group, our customers and ourconsumers.

21. Protecting the environment
Our business relies on a sustainable supply chain. We are committed to minimizing environmental
impacts of our operations, products and packaging and to conserving resources for futuregenerations.

22. Investing in communities
We aim to make a positive contribution to the communities in which we operate.