Customer Harassment Policy｜Japan Pulp & Paper Company Limited

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Customer Harassment Policy

Japan Pulp & Paper Group
Customer Harassment Policy

1. Introduction

The Japan Pulp & Paper Group (“the group”), in accordance with the Japan Pulp & Paper Group Charter of Corporate Behavior, and in order to put the Japan Pulp & Paper Group Sustainability Policy into practice, established the Japan Pulp & Paper Group Code of Conduct for Executives and Employees, which sets out the values and standards of behavior that all executives and employees are expected to share in the performance of their daily duties.

In addition, Article 4 of this Code of Conduct entitled “Respect for Human Rights,” states our commitment not to engage in any form of harassment that undermines the dignity of individuals on the basis of gender, authority, or position, and to strive to build a workplace that does not tolerate any harassment.

At the same time, the group regards unreasonable demands from customers and business partners, as well as speech, behavior, violence, or harassment that infringe upon the dignity and human rights of our executives and employees, as serious issues that must not be condoned or overlooked. Accordingly, in order to respect the human rights of all executives and employees and to continue providing high-quality products and services on a sustainable basis, we have established this Japan Pulp & Paper Group Customer Harassment Policy.

2. Definition of Customer Harassment

The group defines customer harassment in accordance with the Customer Harassment Manual issued by Japan’s Ministry of Health, Labour and Welfare, as complaints, demands, or conduct from customers, business partners, or other stakeholders where the means or manner used to pursue a demand are socially unacceptable in light of the reasonableness of the demand itself (hereinafter referred to as “seriously disruptive conduct”), and where such conduct adversely affects the working environment of executives or employees.

3. Examples of Seriously Disruptive Conduct

The following examples are not exhaustive:

Physical attacks (assault, causing injury, etc.)
Psychological attacks (threats, defamation, slander, insults, abusive language, etc.)
Forcing someone to perform formalized, submissive apologies such as prostrating oneself (e.g., “dogeza,” forced kneeling)
Continuous (repeated), persistent (overly insistent) behavior
Restrictive conduct (refusing to leave premises, occupying facilities, prolonged detention, etc.)
Nitpicking, fault‑finding, or trying to trip up the responding employee over a minor mistake
Demanding special treatment by exploiting a position of superiority
Sexual conduct, including sexual harassment, voyeuristic or non-consensual photography, and other obscene or sexually suggestive behavior
Stalking or lying in wait
Demanding products, services, or money without justifiable reason
Demanding apologies without justifiable reason
Posting personal or other information relating to group executives and employees on SNS or other social media
Photographing or recording video and/or audio of group executives and employees without permission
Making false allegations or threats, such as insinuating that group executives and employees have connections with antisocial or criminal organizations

4. Response to Customer Harassment

If speech or conduct deemed to constitute customer harassment is identified, the group will take a firm stance to protect its executives and employees and may, where necessary, decline to provide products, services, or other business accommodations.

In cases where the conduct is deemed malicious or criminal, we will take firm and decisive action, including legal measures such as reporting the matter to the police, in consultation with external experts, including legal counsel.

Furthermore, if a business partner reports that an executive or employee of the group has engaged in customer harassment, we will work with said business partner to respond appropriately and in good faith.

5. Internal Response Measures

We will provide education and awareness‑raising to group executives and employees regarding customer harassment.
We will establish a framework that enables prompt and appropriate responses to incidents of customer harassment.
Where executives or employees of the group are subjected to customer harassment, we will place the highest priority on their physical and mental safety and health.

6. Request to Customers and Business Partners

The group is committed to building stronger and more positive relationships with customers and business partners. However, if any conduct falls within the scope of customer harassment, we will respond in accordance with this Policy. We kindly ask for your understanding and cooperation.

Established July 1, 2026

Akihiko Watanabe
Representative Director
President & CEO
Japan Pulp & Paper Co., Ltd.