Safe Harbor Privacy Policy

International Safe Harbor Privacy Policy

International Paper, its subsidiaries and affiliated companies (collectively “International Paper”) respect your concerns about privacy. International Paper complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information from European Union member countries and Switzerland. International Paper has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement. To learn more about the Safe Harbor Program, and to view International Paper’s certification, please visit http://www.export.gov/safeharbor/.

Definitions

For the purposes of International Paper’s Safe Harbor Privacy Policy:

“Personally identifiable information” or “PII” is any information that identifies or can be used, directly or indirectly, to identify, a person. PII does not include information that is encoded, anonymized, aggregated or publicly available information that has not been combined with non-public personal information.

“Sensitive personal information” is a subset of PII and is any information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, or trade union membership or concerns an individual’s health or sex life.

“Agent” means any authorized third party that processes PII on behalf of International Paper.

Policy

International Paper follows the Safe Harbor Principles established by the U.S. Department of Commerce. This policy sets forth the principles that International Paper uses to manage the processing of PII that it receives from the EEA and Switzerland:

NOTICE

When International Paper collects PII directly from individuals in the EEA and Switzerland, it will notify them about:

· The type of personal information collected

· The purposes for which it collects and uses the PII

· The types of non-agent third parties to which the company discloses or may disclose the information

· The choices and means the company offers individuals for limiting the use and disclosure of their PII

International Paper will provide this notice to individuals in clear and conspicuous language when the individuals are first asked to provide PII to International Paper, or as soon as practicable thereafter. In any event, International Paper will provide the notice before it uses or discloses the information for a purpose other than that for which it was originally collected.

In some instances, International Paper may process PII in the U.S, at the direction of its customers and does not have a direct relationship with individuals whose PII it processes. Under those circumstances, International Paper’s customers are responsible, pursuant with contractual arrangements with the company, for providing the required notice to individuals.

CHOICE

International Paper must offer individuals the opportunity to choose (opt-out) whether their PII is to be a) disclosed to a non-agent third party, or b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

With regard to PII that constitutes sensitive information, International Paper will provide individuals the opportunity to affirmatively consent (opt-in) to the disclosure of this information to a non-agent third party or the use of this information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

International Paper will provide individuals with reasonable mechanisms to exercise their choices.

Transfers to Third Parties (ONWARD TraNSFERS)

Before disclosing PII to its agents, International Paper will obtain assurances that they will safeguard personal information in a manner that is provides at least the same level of privacy protection as this policy. If International Paper has knowledge that an agent is processing information in a manner contrary to this policy, International Paper will take reasonable steps to prevent or stop such processing or to ensure that the processing is compliant.

ACCESS AND CORRECTION

Upon request, International Paper will provide individuals with reasonable access to their PII. International Paper will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the cases in question, or where the rights of persons other than the individual would be violated.

DATA INTEGRITY

International Paper will use PII only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. International Paper will take reasonable steps to ensure that that PII is reliable for its intended use, accurate, complete and current.

SECURITY

International Paper will take reasonable and appropriate administrative, technical and physical precautions to protect PII in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

ENFORCEMENT AND DISPUTE RESOLUTION

International Paper will provide an annual self-certification of its compliance with the principles to the U.S. Department of Commerce’s Safe Harbor Program.

International Paper is committed to investigating and attempting to resolve privacy concerns in a manner that is consistent with Safe Harbor Principles. Employees who have a question or concern regarding the use or disclosure of PII are encouraged to seek a resolution through their HR representatives or the HelpLine. Other individuals may seek resolution of their questions or complaints by contacting International Paper’s Office of Ethics and Business Practice.

International Paper will cooperate with European Data Protection Authorities for the purpose of handling any unresolved disputes regarding personal data collected in support of the company’s human resources operations.

For concerns related to the company’s commercial operations that cannot be resolved between International Paper and the individual, International Paper will utilize the International Centre for Dispute Resolution of the American Arbitration Association.

Changes to this Safe Harbor Privacy Policy

From time to time, we may make changes in this Privacy Statement to reflect changes in our business or applicable laws. International Paper will post any such changes to its Safe Harbor Policy on this Web site. Please review this Safe Harbor Policy periodically to keep yourself informed of any changes.

Contact Us

Questions or comments regarding this policy should be submitted to International Paper’s Office of Ethics and Business Practice by mail or e-mail as follows:

Chief Ethics & Compliance Officer

International Paper

6400 Poplar Avenue

Memphis, TN 38197

e-mail: ethics@ipaper.com

Individuals also have the option of contacting the company’s HelpLine at 1-800-443-6308.