Printpack Supplier Code of Conduct

Printpack Supplier Code of Conduct

Printpack expects all of its suppliers to comply with the law and act ethically in their dealings. This Supplier Code of Code of Conduct establishes minimum requirements for our suppliers worldwide. Suppliers will not violate this Code directly or indirectly through the use of subcontractors or other intermediaries. Working together, we can achieve great success by doing the right thing.

1. Forced Labor, Slavery and Human Trafficking. 

   Supplier will not engage in or support human trafficking or use or support slavery or slave labor in its supply chain. Supplier shall respect the freedom of movement of its workers and not restrict their movement by controlling identity papers, holding money deposits, or taking any other action to prevent workers from terminating their employment. If workers enter into employment agreements with Supplier, workers should do so voluntarily.

2. Child Labor. 

   Supplier shall not directly (or indirectly through the use of subcontractors) employ any children under 18 years of age unless legal and necessary and unless Supplier complies with the minimum employment age limit defined by national law where the person is working or by International Labor Organization (“ILO”) Convention 138, whichever is higher.

3. Diversity and Inclusion. 

   Supplier will hire, compensate, promote, discipline, and provide other conditions of employment-based solely on an individual’s performance and ability to do the job (except as required under collective bargaining agreements). Supplier will not discriminate based on a person’s legally protected status where that person is employed.

4. Harassment and Abuse. 

   Supplier will provide a workplace free from harassment, which can take many forms, including sexual, verbal, physical, or visual behavior that creates an offensive, hostile, or intimidating environment.

5. Safety and Health. 

   Supplier will

   • endeavor to provide safe working conditions;
   • provide its employees with appropriate protection from exposure to hazardous materials;
   • provide its employees with access to potable water and clean sanitation facilities;
6. Third-Party Representation. 

   Supplier will respect the decision of its employees to join and support a union as well as their decision to refrain from doing so where legally permitted.

7. Working Hours and Compensation. 

   Within the bounds of normal seasonal and other fluctuations in business requirements, Supplier will:

   • maintain a reasonable overall pattern of required working hours and days off for its employees so that total work hours per week do not regularly exceed industry norms;
   • pay fair and timely compensation, including any required premium payments for overtime work
8. Disciplinary Practices. 

   Supplier will not use corporal punishment or other forms of mental or physical coercion as a form of discipline.

9. Business Integrity and Anticorruption. 

   Supplier shall conduct its business fairly, honestly, and ethically, and comply with all applicable laws. Printpack will not tolerate bribery or corrupt practices by its officers, employees, or anyone acting on its behalf. Accordingly, Supplier:

   • Will not offer, promise, pay, or give any money, bribe, or advantage, directly or indirectly, to Printpack employees, officers, or anyone acting on their behalf, for illegal purposes.
   • Will not offer or give any bribe, advantage, or consideration to a Public Official in connection with its dealings with Printpack.
   • Will immediately report any request for a bribe or offer of consideration received from Printpack representatives or a Public Official.

   Supplier will promote honesty and integrity among its employees by providing training and guidance on ethical business conduct.

10. Screening for Sanctioned and Restricted Parties. 

    When accepting Printpack’s Supplier Code of Conduct, Supplier must disclose the following:

    • Have you ever been debarred by the U.S. Government? (YES/NO)
    • Have you ever had trading privileges, export, or business licenses revoked or been subjected to criminal prosecution? (YES/NO)
    • Are any of your officers, directors, partners, or shareholders currently or previously subject to U.S. Government sanctions? (YES/NO)
11. Environment and Sustainability. 

    Supplier shall continuously improve its environmental practices to minimize the impact of its operations on the environment.

12. Conflicts of Interest. 

    Printpack employees must act in the company’s best interest, and Suppliers must avoid conflicts of interest. Suppliers shall:

    • Not employ or make payments to Printpack employees during ongoing transactions.
    • Disclose relationships with Printpack employees that could create a conflict, such as family or personal ties, or ensure Printpack employees disclose them.
13. Reporting Obligation. 

    Suppliers who suspect illegal or improper conduct by Printpack employees or representatives should report the matter to Printpack through its Ethics & Compliance Officer or General Counsel at +1 404-460-7000. Alternatively, they may report via the web-based reporting service at EthicsPoint.

    Honest reporting will not impact the Supplier’s relationship with Printpack.

14. Audit Rights. 

    Printpack reserves the right to audit the Supplier’s compliance with this Code of Conduct. Upon request, Suppliers must certify compliance with this Code or provide evidence of a similar compliance program. Non-compliance may result in termination of agreements or relationships with Printpack.

Revised June 2016