Establishment of “Polyplastics Group Competition Law Compliance Policy” /

News 2 Vol.68

In September 2014, Polyplastics established the “Polyplastics Group Competition Law Compliance Policy.” (the “Policy”)

As the Polyplastics Group is expanding its business to a global scale, Polyplastics have been holding the three tasks to be addressed from the perspective of insuring compliance with competition laws.

1. Need to ensure compliance with competition laws from a global perspective
85 countries throughout the world, including 17 countries in the Asia-Pacific region, have relevant laws.

2. Need to provide a unified compliance policy on competition laws for all companies in the Polyplastics Group
The existing method of education and training that employees learn enormous and detailed prohibited matters should be transformed.

3. Need to establish a simple guidance for avoidance of serious major risks
Avoidance of conflict with hardcore cartels (resale price maintenance by cartels) has a priority.

The Policy provides specific codes of conduct to enable each employee to act in compliance with competition laws, as stated in paragraph 6 of the Polyplastics Group Conduct Policy, “We shall act in accordance with the principles of fair and free competition, while engaging in sincere business transactions.”

To help employees to correctly understand the policy, the PPC Legal Department prepared and distributed a booklet titled “Polyplastics Group Competition Law Compliance Policy” and followed up with compliance seminars held at each of Polyplastics Group companies in the Asia-Pacific region between November 2014 and January 2015.

Many employees at each of the Group companies attended the seminar. The seminars did not only present commentary by persons from the PPC Legal Department on the policy, but gave employees who participated the opportunity to ask questions about things they encounter in their daily work that they feel are related to compliance with competition laws. The PPC Legal Department answered each of the questions by making reference to the Policy and lively debate ensued over interpretation of the Policy.

The PPC Legal Department will make every effort to ensure compliance with competition laws under “The Polyplastics Group Competition Law Compliance Policy”.