Policy Statement on Corrupt Practices

G.A. Paper International Inc. and its subsidiaries and affiliates “the Company” maintains exacting standards of business ethics and conduct at home and abroad. In doing so, the Company is subject to the terms and provisions of laws in both Canada and the U.S.A. which prohibit companies and individuals, either directly or indirectly, from corruptly offering, paying, promising to pay or otherwise transferring anything of value to a Foreign Official to facilitate, obtain or retain business or maintain an improper advantage. These laws also stipulate that it is unlawful to make payments to an agent, representative or other intermediary(ies) while knowing or having reason to know that any part of the payment will be used in breach of the law. The responsibility for attempting to bribe officials applies to companies and persons operating from North America. Being out of the country does not protect those who may be involved.

Policy

Neither G. A. Paper International nor any of its employees, agents or representatives shall offer, make, promise or authorize a payment to any official or other person or entity which would violate any of the these laws or which would, in any manner, subject the Company to allegations of improper conduct.