The Mondi Code of Business Ethics states clearly the key principles and values that guide our conduct and support all of our policies, principles and guidelines. In 2009, the Code was reviewed and judged to be relevant and appropriate.

The Code of Business Ethics applies to all Mondi employees. It comprises five 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 its stakeholders – 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 also encourage all those with whom it does business to observe the same principles.

The Code is supported and explained more fully through a number of detailed guidelines and policies covering competition compliance, conflicts of interest, dealing in securities, gifts and bribes, and political donations.

Competition compliance

We take positive action to make sure our employees understand all relevant competition law requirements and operate a system of self-certification, assurance and audits. In 2009, there were no competition compliance irregularities relating to Mondi businesses.

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 those connected to them are announced to the Johannesburg Stock Exchange and London Stock Exchange immediately. 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.

‘Speakout’ campaign

In 2008 we reviewed, refreshed and relaunched our whistleblowing programme, changing its name from ‘Speak Up’ to ‘Speakout’. The programme gives our employees and external partners the opportunity to report instances of dishonesty, discrimination or dangerous behaviour contrary to our values in complete confidentiality.

Confidentiality is key to the success of any whistleblowing scheme: providing reassurance to employees that they can raise concerns, which may involved more senior employees or their line manager, without fear of recrimination. To this end, Speakout is managed on our behalf by a third party, its independence and effectiveness monitored regularly by the DLC audit committee.

Employees and partners can access Speakout via a 24-hour multi-language phone service to which Mondi has no direct access. The third-party administrators of the system inform us about concerns, and we then have the opportunity to investigate these and respond accordingly. We have strict guidelines in place to ensure that the programme is not abused by any individual.

Last change: 24/03/2010