SAPPI LTD (SAP) 6-K

Interest in contracts
The Sappi Group has a policy regulating disclosure of interest in contracts. The policy dictates that all employees disclose any interest in contracts to assess
any possible conflict of interest. The policy also dictates that directors and senior officers of the group must disclose any interest in contracts as well as other
appointments to assess any conflict of interest in fiduciary duties. Meyer Feldberg, a non-executive director of the company, disclosed his role as senior
advisor at an affiliated company of the Financial Advisor and Transaction Sponsor. His interest is not regarded as significant. During the year under review,
other than Prof. Meyer Feldberg, there has been no significant interest in any material contract or arrangement entered into by the company or its subsidiaries.
Insider trading
The Company has a code of conduct for dealing in company securities. No employee of Sappi in possession of material non-public information in respect of
Sappi or any of its Subsidiaries, nor any member of his/her family or household may, at any time, buy or sell securities of Sappi or its Subsidiaries, or engage
in any other action to take advantage of such information. All officers, directors and employees who have access to unpublished price-sensitive information
are precluded from trading in Sappi securities during “closed periods”, which apply from the end of the financial quarters in March, June, September and
December respectively, until two full Business Days after the release of the results for the respective quarters. Prior to dealing in Sappi securities (even
outside closed periods), clearance should be obtained from the Sappi chairman through the Sappi group secretary. In practice the chairman clears the
transactions of the directors of Sappi and the chairman himself requires the clearance of the audit committee chairman for his own transactions.
Fraud and illegal acts
The Sappi Group does not engage in or accept or condone the engaging in of any illegal acts in the conduct of its business. The directors’ policy is to actively
pursue and encourage prosecution of perpetrators of fraudulent or other illegal activities should they become aware of any such acts. The group has
implemented a fraud line to facilitate reporting any fraud or illegal acts which is externally managed and administered.
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