■ Policy on the Prevention of Deforestation and Responsible Land Use

Article 1 (Purpose)

 

Wismettac Group (hereinafter referred to as  “the Company”) hereby establishes this Policy on the Prevention of Deforestation and Responsible Land Use (hereinafter referred to as this “Policy”) pursuant to the Group’s Basic Sustainability Policy, for the purpose of identifying, assessing, managing, and mitigating risks relating to deforestation and land use within the Group companies and relevant supply chains.

 

  • The Group shall endeavor to implement the following measures and promote sustainable procurement:
  • Complying with environmental laws and regulations, including those relating to deforestation and land use, in producing countries and other applicable jurisdictions;
  • Avoiding any contribution to deforestation occurring after the applicable cut-off date, being the date prescribed under each applicable law or regulation; and
  • Enhancing supply chain transparency, taking into account the Group’s role, position, and degree of influence within the relevant supply chain.

This Policy constitutes part of the Group’s overall risk management framework and is intended to support the Group’s compliance with applicable laws and regulations, including EU Deforestation Regulation (EU) 2023/1115 (the “EUDR”).
 

Article 2 (Scope of Application)


Under this Policy, the Group shall conduct focused and proportionate due diligence and verification, based on a risk-based approach, with respect to products handled by the Group that are assessed to present a heightened risk of deforestation.
In particular, the Group shall address, in accordance with this Policy, soy, palm oil, cocoa, coffee, cattle, including beef and leather, rubber, timber, and relevant derivative products that fall within the scope of the EUDR.
The Group shall also request suppliers involved in such products to understand, acknowledge, and cooperate with the intent and requirements of this Policy, taking into account the Group’s position and sphere of influence within the supply chain.
 

Article 3 (Governance)

 

Risks relating to deforestation and land use, and initiatives implemented under this Policy, shall be managed through the Group’s existing governance and risk management structure.

 

  • The Compliance Office shall deliberate on and monitor material risks and opportunities relating to deforestation and land use through the Group’s existing risk management process.
  • The heads of departments designated by the Compliance Office shall be responsible for establishing, implementing, and maintaining the processes and management systems necessary to give effect to this Policy.
  • Any non-compliance with this Policy by suppliers shall be identified, reported, and addressed through risk-based corrective measures in accordance with the Group’s  Code of Business Ethics, Basic Sustainability Policy, and other relevant policies, and shall be managed within the Group’s governance framework.

 

Article 4 (Initiatives)

 

4.1 (Compliance with Laws and Regulations)
The Group shall handle commodities that are produced in compliance with environmental laws and regulations, including those relating to deforestation and land use, as well as other applicable laws and regulations in the relevant jurisdictions.

 

4.2 (Risk-Based Approach)
The Group shall identify, assess, and consider appropriate mitigation measures for risks relating to deforestation and land use by applying a risk-based approach, taking into account factors such as product category, geographic context, supplier information, and the availability and reliability of relevant data.

 

4.3 (Supply Chain)
The Group shall seek to collaborate with suppliers to enhance supply chain transparency and address identified risks, including through information collection and risk assessment. Where any matter requiring improvement is identified, including any violation or potential violation of applicable laws or regulations, the Group shall verify the supplier’s compliance status and take appropriate actions, including engagement with the supplier regarding the consideration and implementation of corrective measures.

 

4.4 (Traceability)
Recognizing that the complexity of traceability and the availability of relevant data vary across supply chains, the Group shall endeavor to continuously improve traceability, including the collection and management of information concerning country of production or origin, as applicable.
 

Article 5 (Monitoring)


For the purpose of monitoring the appropriate implementation and effectiveness of this Policy, the Compliance Office shall continuously ascertain the status of implementation through existing management processes and shall periodically review regulatory developments, enforcement practices, available data and tools, and the level of supply chain transparency.
 

October 1, 2026

Nishimoto Co., Ltd.