Equal Employment Opportunity Policy

It is a Principle of Excellence at International Paper that "we value diversity and treat each other with dignity and respect." As employees of International Paper, you and I have the personal responsibility to live up to that Principle.
	All of us need to create an atmosphere every day where every International Paper employee knows that he or she is valued as an individual, and is treated with dignity and respect. Our Policy on Equal Employment Opportunity is an important reaffirmation not only of the International Paper Agenda, but also of the law. As stated in our Principles of Excellence, "we honor the letter and the spirit of the law." POLICY AGAINST DISCRIMINATION Applicants for employment and all employees throughout their careers with the company will not be discriminated against because of race, color, religion, sex, sexual orientation, marital status, age, disability or national origin with respect to any term or condition of employment.
This includes, for example, recruitment and hiring, training and development, compensation, transfer and promotion, and discipline and discharge. The same principles will be applied in the employment of disabled veterans and Vietnam era veterans.
POLICY AGAINST HARASSMENT Freedom from discrimination includes freedom from any form of harassment due to a person's race, color, religion, sex (whether or not sexual in nature), sexual orientation, marital status, age, national origin, disability, or veteran status. This conduct is prohibited whether committed by managerial or non-managerial employees, contractors, vendors or customers. Examples of prohibited conduct include:
verbal conduct (for example, racial or sexual epithets, foul language, unwanted sexual flirtations, commentaries about a person's body, ethnic jokes, derogatory statements or slurs) physical conduct (for example, improper touching or assault) visual harassment (for example, racially or sexually explicit or derogatory posters, cartoons or drawings, or obscene gestures)
Even if such actions do not rise to the level of legally actionable conduct, they nonetheless are prohibited in our workplace. In addition, offering or implying to offer employment benefits in exchange for sexual favors is prohibited. Reprisals for a refusal to respond to sexual advances also are prohibited. This is the most blatant form of harassment. Therefore, no supervisor or manager shall threaten or insinuate, either explicitly or implicitly, that an employee's submission to or rejection of sexual advances will in any way influence any personnel decision involving that employee. As stated in the EEOC's guidelines, unwelcome sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature constitute sexual harassment when (1) submission to such conduct is made explicitly or implicitly a term or condition of an individual's employment, (2) submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual, or (3) such conduct has the purpose or effect of unreasonably interfering with an individual's work performance or creating an intimidating, hostile, or offensive working environment.
COMPLAINT PROCEDURES If you have a good faith belief that you or any other employee has been the victim of harassment, discrimination or any other violation of this policy, report the conduct to management. Any such report should be made promptly so that, whenever possible, any problem can be remedied at the earliest opportunity. You may, as you believe appropriate under the circumstances, report incidents directly to:
your supervisor or manager your supervisor's or manager's superior a Human Resources Representative the HelpLine/Compliance Line (1-800-443-6308) or the Director of Ethics and Business Practice (1-914-397-1509)
You are not required to first report the incident to your supervisor or manager; you may bypass the chain of command and choose from the listed procedures. Complaints are not required to be in any particular form and may be oral or written. All reports of such conduct will be investigated promptly, handled as confidentially as possible consistent with doing an appropriate investigation, and dealt with appropriately. Employees who are found to have violated this policy are subject to disciplinary measures, up to and including termination. Such violations can also result in personal legal and financial liability.
NO RETALIATION Threats or acts of retaliation or retribution against employees who make use of the complaint procedures or who provide information about such complaints will not be tolerated. Use the procedures described above to report any such actions
MANAGEMENT RESPONSIBILITIES It is the responsibility of persons in management positions (1) to bring this policy to the attention of all employees, (2) to ensure that all personnel actions are administered in accordance with this policy, and (3) to bring to the attention of their supervisor or manager, their Human Resources Representative, the Director of Ethics and Business Practice, or the Legal Department any violation of the policy of which they become aware
John Faraci Chairman & Chief Executive Officer