EVERGREEN PACKAGING
CODE OF BUSINESS ETHICS
EVERGREEN PACKAGING’S CODE OF BUSINESS ETHICS
APPLIES TO ALL EMPLOYEES.
RESPONSIBILITY
The following standards, policies and procedures, when taken together, define our ethics
as a company. They apply to all employees. Our ethics are not simply rules and
regulations; rather, they describe for us the right way of doing business and of relating to
others. Often, they reflect standard legal concepts. Always, they represent basic values
and beliefs about how we expect ourselves and our fellow employees to treat each other,
as well as our customers, suppliers, and the people who live and work in the
communities, states and countries where the company has operations. We uphold the
highest ethical standards and are accountable in all that we do.
RESPECT
Good human relations lead to good employee relations. Treating each other and all of our
company stakeholders with dignity and respect is how we practice good human relations.
Expecting fellow workers to perform their jobs with integrity and expertise is our
company norm. Abusive, deceitful, or violent behavior will not be tolerated.
We have a diverse workforce in our company. We believe that differences among us
should be valued, so that we all can work in an environment that supports growth and our
company goals. We believe that we will all benefit from the creativity, varied
perspective, innovation, and energy that arise out of our diverse workforce.
Employees must not harass, discriminate, or support others who harass and discriminate
against colleagues or members of the public for any reason, including without limitation,
sex, social orientation, pregnancy, marital status, age, race (including their color,
nationality, descent, ethnic or religious background), physical or intellectual impairment.
COMPLIANCE AND ACCOUNTIBILITY
ENVIRONMENTAL, HEALTH AND SAFETY
We are committed to providing a safe and healthy work environment and this means
operating in compliance with applicable health and safety regulations and laws. It also
means the accurate and timely reporting of any incident required to be reported.
We do not tolerate any acts or verbal or physical behavior that could lead to or cause
workplace violence. The health and safety of our employees, as well as the expectation of
quality by our customers, require that each employee works free from the influence of
any substance that could prevent or impede safe and effective work activities. We are
each responsible for our own safety, and that of our co-workers.
Employees whose work affects environmental compliance must be completely familiar
with the permits, laws, and regulations that apply to their work. In the area of safety, all
employees are responsible for their own safety and the safety of co-workers. It is
imperative that employees know the safety procedures and regulations for their
workplace
HONORING THE LETTER AND SPIRIT OF THE LAW
Antitrust
We believe in free and open competition. In all of the countries where we operate, strict
laws are in force prohibiting collusive or unfair business behavior that restricts free
competition. We are not permitted to enter into agreements with competitors to fix prices,
terms of sale or production output. Also, attempts by suppliers to discriminate in prices or
terms of sale between customers, or to otherwise restrict the freedom of our customers to
compete, can sometimes be illegal. Legal issues can also arise from refusal to deal with
customers or competitors. Failure to adhere to these laws could result in significant
penalties to both the employee and the company. The company Legal Department can
answer any questions you may have about antitrust and competition issues.
Copyrights
We respect and protect intellectual property, whether it belongs to us or to others.
Copyright laws protect intellectual property, including written and electronic materials,
computer software, CD-ROM and videotape products. We obey these laws, and are
prohibited from copying or distributing copyrighted materials without the permission of
the copyright owner.
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Political Activities/Foreign Corrupt Practices Act
Many employees actively participate in the political life of their communities, and the
company encourages that participation. But employees may not use company resources
and/or assets to support their choice of political party, candidate or cause.
As a company, we take positions on political issues and lobby on behalf of our interests
and goals, but always in strict conformance with applicable laws. Employees who
communicate with government officials should always contact the Legal Department to
make sure that they fully understand the laws and regulations in question.
When doing business outside the United States, Evergreen Packaging and its employees
honor local laws and applicable U.S. laws, including the Foreign Corrupt Practices Act
(the FCPA). This law, in general, prohibits our company and its employees from offering,
promising to pay or authorizing the payment of money or anything else of value to nonU.S. officials, parties or candidates in order to influence their acts or decisions. The rules
are complex, so you should always seek advice from the Legal Department before acting.
Do not act without such advice.
Embargoes and Boycotts
The United States has strict export control laws prohibiting exports to certain countries
from the U.S. and, in some cases, from our operations outside the United States. Other
countries may also prevent companies from conducting business with certain countries.
These actions are embargoes. Additionally, United States laws prohibit any action that
might help facilitate boycotts. Boycott problems may arise in the context of sales, letters
of credit, bid proposals and shipping documents. You should seek help immediately from
the Legal Department if you think that someone is asking you to participate in a boycott
or break an embargo.
GIFTS
We believe that no gift, favor or entertainment should be accepted or provided if it will
obligate, or appear to obligate, the receiver. The giving or accepting of bribes or
inappropriate, lavish or repeated gifts or other benefits is always prohibited. Similarly,
requesting or soliciting personal gifts or services, or requesting contributions from
vendors, suppliers or other business partners, is prohibited. In general, providing or
accepting normal sales promotion items, occasional meals or other non-cash items of
minimal commercial value is appropriate. In countries where gifts are accepted and
expected by local custom, you should always seek advice from the Legal Department
before acting.
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RECORDS AND INFORMATION MANAGEMENT
Business records and documents should be retained or destroyed only according to the
company’s records management policy. This policy provides that each company location
has schedules and regulations covering retention of records, including printed files and
those maintained electronically. Strict compliance with these policies is very important
for the protection of the company and individual employees.
SECURITY OF CONFIDENTIAL INFORMATION
Information is one of our company’s most valuable assets. Employees are responsible for
protecting the company’s confidential information, which includes new product and
marketing plans, manufacturing processes, research and development ideas and
information about potential company investments. This responsibility does not end when
employment is terminated. In turn, confidential information that new employees and
consultants bring with them from another company has to remain confidential, and
current employees must ensure that they do not receive or use confidential or proprietary
information belonging to another company or person.
Employees are to make sure that confidential and sensitive information cannot be
accessed by unauthorized persons. Sensitive material should be securely stored overnight
or when unattended. Employees must ensure that confidential information is only
disclosed or discussed with people who are authorized to have access to it. It is
considered a serious act of misconduct to deliberately release confidential documents or
information to unauthorized persons, and may incur disciplinary action, up to and
including termination.
CONFLICT OF INTEREST
Potential for conflict of interest arises when it is likely that an employee could be
influenced, or it could be perceived that they are influenced, by a personal interest when
carrying out their duties. Conflicts of interest that lead to biased decision-making may
constitute corrupt conduct. Some situations that may give rise to a conflict of interest
include situations where an employee has:
1. financial interests in a matter the company deals with
2. directorships/management of outside organizations
3. membership of boards of outside organizations
4. personal relationships with people the company deals with which go
beyond the level of a professional working relationship
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5. secondary employment, business, commercial, or other activities outside
of the workplace which impact on the employee’s duty and obligations to
the company
6. access to information that can be used for personal gain
An individual employee may often be the only person aware of the potential for conflict.
It is their responsibility to avoid any conflict from arising that could compromise their
ability to perform their duties impartially. They must report any potential or actual
conflicts of interest to their manager. If an employee is uncertain whether a conflict
exists, they should discuss that matter with their manager and attempt to resolve any
conflicts that may exist.
USE OF COMPANY RESOURCES
Requests to use resources of the company should be referred to management for
approval. If employees are authorized to use such resources outside core business times
they must take responsibility for maintaining, replacing, and safeguarding the property
and following any special directions or conditions that apply. Employees using such
resources without obtaining prior approval could face disciplinary and/or criminal action.
Company resources are not to be used for any private commercial purposes.
REPORTING MATTERS OF CONCERN
Employees are encouraged to raise any matters of concern in good faith with their
manager, the head of their facility or department, Legal, Human Resources, or Corporate
Audit without fear of retribution.
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I ACKNOWLEDGE I HAVE READ THIS AGREEMENT AND AGREE TO ABIDE
BY ALL OF THE CONDITIONS AND AGREEMENTS.
Employee Signature:
___________________________________
Employee’s printed or typed name: ___________________________________
Employee Number:
___________________________________
Date:
___________________________________
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