Compliance, business conduct and ethics

Objectives of Sonoco Metal Packaging EMEA

• Establish and maintain a culture of compliance, with every employee trained and engaged.
• Encourage employees to report unethical behaviour and assess ethical concerns with neutrality.
• Ensure that our partners adhere to our Compliance Policies.
• Strictly comply with applicable laws and regulations and ensure that our business partners
  comply with applicable laws and regulations.

Sonoco Metal Packaging EMEA’s culture of compliance

Sonoco Metal Packaging EMEA is committed to doing business ethically, with integrity, and in compliance with all applicable laws. We always endeavour to conduct business responsibly and in accordance with our values. To ensure the practice of these commitments, Sonoco Metal Packaging EMEA has implemented a robust

Compliance Programme designed to define, promote, and ensure (through a system of controls) ethical business operations and uniformity in conduct standards across our company. The programme has four broad objectives:
• Participation of every employee in identifying and addressing potential compliance issues.
• Providing ongoing awareness and compliance training to employees regarding their obligations and applicable
laws.
• Implementing a system to monitor, audit, and review the Compliance Programme.
• Implement procedures for reporting and investigating suspected violations of the company’s Code of Business Conduct and Ethics, and implementing corrective action, including disciplinary measures if appropriate.

The Compliance Programme and its objectives are overseen by the company’s Compliance Management Committee, comprised of the company’s CEO, CFO and Compliance Officer, with the support of external counsel, as required. The implementation of the Compliance Programme is managed by dedicated staff members who ensure appropriate training for employees, in line with their respective positions and responsibilities at Sonoco Metal Packaging EMEA.

Alongside ongoing training sessions, the company’s senior management and other staff members communicate the various aspects of the Compliance Programme on a regular basis to build awareness among employees of the importance of compliance within the business. The policies and requirements of the Compliance Programme are outlined and specified in the Code of Business Conduct and Ethics (“the Code”), the centrepiece of the programme. The Code encompasses a series of policies that are applicable to all Sonoco Metal Packaging EMEA’s employees, suppliers, and third-party service providers.

The topics outlined and covered in the Code are:

• Conflicts of interest and corporate opportunities
• Dealings abroad
• Anti- corruption
• Antitrust and competition
• Environment, Health, and Safety
• Confidential information and trade secrets
• Fair treatment of people including equal opportunity, protection against harassment and discrimination, and human rights
• Fair dealing, and veracity in reports and records
• Financial reporting
• Public affairs, including political contributions
• Employee obligations
• Compliance and reporting procedures, including detailed information and contacts for reporting any suspected violation of business ethics, policies, or procedures
• A statement of “No retaliation” policy

All employees joining Sonoco Metal Packaging EMEA receive a copy of the Code as part of their onboarding process. They are expected to read it, understand it within the context of their functions at the company, and sign it. Employees are also required to read and accept the terms of the Code as part of the company’s mandatory annual compliance training.

Sonoco Metal Packaging EMEA has established an Ethics Hotline as a part of its Whistleblowing system through which Employees are encouraged to report behaviour that is inconsistent with the company’s Code and other compliance Policies. Reports may also be made through their supervisor, the Compliance Officer, or the Legal department. The Ethics Hotline is available in 15 languages across the company’s sites. We regularly share the details to access our Ethics Hotline and website with employees through compliance training activities, on our intranet, and on our public website. Accessing the hotline enables employees, suppliers and business partners to raise concerns anonymously and confidentially. These concerns are investigated promptly and thoroughly by an appointed team. The number of alerts reported through the hotline and whistleblowing system underscores the awareness of the tool among our employees and third parties.

Sonoco Metal Packaging EMEA Compliance is pleased to confirm that the culture of compliance is well-anchored within the company:
none of the alerts reported to the hotline has raised a compliance concern. Sonoco Metal Packaging EMEA will continue to publicise the existence of the hotline and promote its proper use.

Compliance and Sonoco Metal Packaging EMEA’s business partners

Sonoco Metal Packaging EMEA considers as business partners any joint venture partner, distributor/dealer, agent, consultant, or any other third party engaged to act on behalf of Sonoco Metal Packaging EMEA in commercial matters. The laws of many countries require Sonoco Metal Packaging EMEA to be aware of the business practices of its business partners. To that end, Sonoco Metal Packaging EMEA has created specific procedures to minimise the likelihood of bribery and corruption and promote compliance with economic sanctions, export controls, anti-money laundering, and other international trade laws.

Thorough due diligence is required before appointing or onboarding any new Sonoco Metal Packaging EMEA business partner. The initial vetting of a new business partner is done by the employee responsible for the relationship. Sonoco Metal Packaging EMEA’s legal department must then ensure that the necessary due diligence has been completed, the results are satisfactory, and a written agreement has been signed. The procedures put in place are strictly followed by Sonoco Metal Packaging EMEA employees. The company’s legal department is regularly informed of any potential developments in transactions with business partners that may give rise to compliance concerns.

Anti-bribery and anti-corruption

Bribery and corruption matters are covered in our Code, as well as by a separate specific policy. The Anti-Bribery/ Anti Corruption Policy (the “Anticorruption Policy”) applies to all Sonoco Metal Packaging EMEA companies and employees (both permanent or temporary), and to all representatives acting on behalf of Sonoco Metal Packaging EMEA, including business partners. Our Anti-Corruption Policy covers compliance with all anti-bribery and anti-corruption laws applicable to Sonoco Metal Packaging EMEA, including the Sapin II Law, the UK Bribery Act, and the U.S. Foreign Corrupt Practices Act (the “FCPA”). Relevant employees also receive regular compulsory anti-bribery and anticorruption training, through which they are required to review the Policy and certify that they understand it and will comply with it and applicable law accordingly.

Anti-Trust

Sonoco Metal Packaging EMEA is fully committed to a free and competitive marketplace. We comply with the principles of EU, U.S., and other countries’ laws regulating competition. Sonoco Metal Packaging EMEA has established a Competition Law Compliance Policy that aims to educate our employees on anti-trust matters, and the accepted and prohibited practices during our operations. Considering the constant evolution of competition law and practice, the company’s Legal Department regularly organises specific training modules for colleagues whose roles may expose them to competition law risk. Given the importance and sensitivity of this subject, competition law training is provided by specialised external counsel.

Trade compliance

Sonoco Metal Packaging EMEA’s International Trade Compliance Policy outlines our obligations for complying with international trade laws that touch on exports, economic sanctions, and other laws applicable to our business. Our Policy also sets forth the processes to follow when engaging in any transaction with a customer, supplier, counterparty or business party in certain countries. This Policy provides corporate oversight of the process, detailing specific obligations including but not limited to due diligence procedures, screening, country risk assessments, and product risk assessment. Sonoco Metal Packaging EMEA constantly monitors its operations to ensure conformity with the ongoing evolution of economic sanctions and trade regulations in force.