Code of Business Ethics

This Code applies to Mondi plc, Mondi Limited and their respective subsidiary companies (together “Mondi”). The Code sets out the five fundamental ethical principles that govern the way in which Mondi and its employees will conduct business.

The Five Mondi Principles

• Legal Compliance
  Mondi will comply with all applicable laws and regulations.
• Honesty and Integrity
  Mondi will observe the highest standards of honesty and integrity.
• Human Rights
  Mondi will respect the Universal Declaration of Human Rights.
• Stakeholders
  Mondi will have due regard to the interests of all its stakeholders including shareholders, employees, customers, business partners and communities.
• Sustainability
  Mondi will conduct its business sustainably, ensuring safety, health and the protection of the environment.

Mondi will encourage all those with whom it does business to observe the same principles.

The detailed application of these principles is documented in Mondi’s policies and procedures, in particular the Mondi Sustainable Development Policy.

Dealing in securities

A share dealing code based on regulatory and governance best practice covers securities in Mondi Limited and Mondi plc. This sets out restrictions regarding share dealing and access to price-sensitive information for directors, senior management and other key employees. All dealings by directors, employees who discharge managerial responsibilities and their connected persons are announced to the JSE and LSE as they occur. The details of directors’ interests in shares of Mondi Limited and Mondi plc are reported in our Annual Report.

Political donations, gifts and bribes

No Mondi Group companies make contributions or donations for political purposes. Corrupt practices, including bribery and facilitation payments, are also strictly prohibited. We issue detailed guidelines to help employees understand and follow the rules governing gifts, bribes and conflicts of interest. Mondi is satisfied that any lobbying undertaken is in line with the Group's business ethics and internal policies.

Corruption

Corruption is strictly prohibited within the Group. The Group’s approach to corruption is published in corporate brochures, newsletters and on the Group’s website.
Against the background of the UK Bribery Act which took effect in July 2011, the Group reviewed and updated its anti-corruption policy and procedures resulting in a new Business Integrity Policy that is being implemented across the organisation.

Speakout programme

Speakout is a confidential reporting tool for employees and external partners. The service is designed to support Mondi's corporate commitment to ethical, transparent business practice and conduct, as set out in our Code of Business Ethics. Stakeholders may use this service in complete confidentiality to raise any concerns about behaviour or activities that they believe may conflict with our business ethics, such as dishonesty, discrimination or dangerous behaviour contrary to our values. The process is not designed to replace existing reporting lines but recognises that there are specific times when these may not be appropriate.

As we understand that confidentiality is key to the success of any whistle-blowing scheme, we provide assurance to employees that they can raise concerns that may involve more senior employees or their line manager without fear of recrimination. To achieve this, Speakout is managed on our behalf by a third party, its independence and effectiveness monitored regularly by the DLC audit committee.

Mondi’s internal audit function ensures that management at an appropriate level is informed about reported issues and that reported risks are adequately managed. Summary information on all reported issues and the status on all open items are provided to the Mondi Boards and the DLC audit committee.

The free-of-charge Speakout line is available on a 24-hour, 7 day-a-week, multi-language basis. Mondi management does not have oversight of this line and its functions; the third-party administrators advise Mondi of any issues, which we then investigate and respond to within 14 days.

In 2010, there were 47 Speakout messages worldwide (nearly 50% of these related to process inefficiencies, most of them accusing the local management of managing badly, 30% related to fraud and/or misconduct and 13% to human resources issues like job promotion, overtime or vacation policies). All messages were forwarded to the responsible Mondi management which investigated them and reacted adequately in each case. In some instances the problem could not be sufficiently investigated because the information given was incomplete. In these cases the caller was requested to supplement his/her Speakout message via the Hotline. In many other cases, the accusations could not be substantiated. However, there have also been a few cases where Internal Audit carried out further investigations on site or where there were personal consequences for management.

Code of Conduct for Mondi Group suppliers

To ensure that suppliers to the Mondi Group subscribe and adhere to the way we do business, we have implemented a code of conduct for suppliers.

Last change: 20/12/2011