Code of
Business Conduct
The guiding principles
for ensuring the highest
ethical standards at
Solo Cup Company
CODE OF BUSINESS CONDUCT
Page 2 of 19
September 2010
A MESSAGE TO ALL SOLO CUP EMPLOYEES
As our business changes and grows, it is important to revisit from time to time the most
important tenets of how we operate our business, as well as our obligations to the Company
and to each other. These are captured in our Code of Business Conduct which has been
refreshed and updated for you in the following pages.
Our Code of Business Conduct has five governing principles:
1. Be fair and ethical when interacting with customers, competitors and suppliers; in
particular, comply with all applicable laws.
2. Treat your co-workers with dignity and respect.
3. Provide accurate financial disclosure and protect Solo’s confidential information.
4. Avoid conflicts of interest and the appearance of improper influence.
5. Consider the potential for misperception when engaging in political activities or with
public officials.
These principles embody decision-making based on integrity, honesty and transparency, all of
which are critical to productive business relationships. The principles provide guidelines for
behavior with co-workers, customers, suppliers and business partners of all types which should
be followed by every Solo employee. Of course, in both the United States and other countries,
our Code of Business Conduct is supported by policies which provide more detailed information,
and you are responsible for knowing and complying with these policies.
As important as it is to abide by our Code of Business Conduct, it is equally important to speak
up if you see the Code being violated. We all have a responsibility to hold each other to the
highest ethical standards. The Ethics Helpline is available should you have a serious concern
about a violation of the Code or the law that you are not comfortable discussing elsewhere.
Please read through this Code of Business Conduct carefully and completely. As an employee,
you are expected to fully understand the Code and your obligations under it. Thank you for
continued dedication to our Company and to performing to the highest ethical standards.
Sincerely,
Robert M. Korzenski
President & Chief Executive Officer
Solo Cup Company
Solo Cup Company
CODE OF BUSINESS CONDUCT
Page 3 of 19
September 2010
Table of Contents
Make Yourself Heard.................................................................................................................4
5 Governing Principles .............................................................................................................5
Principle No. 1: Be Fair and Ethical ........................................................................................6
Competition Laws ....................................................................................................................6
Laws Relating to Foreign Operations .......................................................................................6
Acquiring a Competitor’s Confidential Information ...................................................................7
Trade Compliance ...................................................................................................................7
Product Quality and Regulatory Compliance ...........................................................................7
When the Government is a Customer ......................................................................................8
Prohibition of Foreign Corrupt Practices ..................................................................................8
Supplier Relationships .............................................................................................................9
Government Inquiries ..............................................................................................................9
Advertising and Promotion of Products ....................................................................................9
Environmental Compliance ....................................................................................................10
Privacy ..................................................................................................................................10
Principle No. 2: Treat Your Co-workers with Dignity and Respect ..................................... 10
Non-Discrimination and Diversity ...........................................................................................10
Workplace Harassment .........................................................................................................11
Retaliation .............................................................................................................................11
Alcohol and Drug Free Workplace .........................................................................................11
Environmental, Health and Safety .........................................................................................12
Minimum Hiring Age and Child Labor ....................................................................................12
Employee Privacy ..................................................................................................................12
Principle No. 3: Provide Accurate Disclosure and Protect Solo Cup’s Confidential and
Proprietary Information ..........................................................................................................12
Accurate Books and Records, Including Financial Disclosure ................................................ 12
Use of Company Assets ........................................................................................................13
Confidential Information, Including Proprietary Information and Trade Secrets ...................... 13
Patents, Trademarks and Copyrights.....................................................................................14
Duty of Loyalty and Post-Employment Duties Not to Engage in Unfair Competition or
Solicitation .............................................................................................................................14
Electronic Media Use and Network Security ..........................................................................15
Personal Electronic Media Use ..............................................................................................16
Social Media ..........................................................................................................................16
Records Management and Storage .......................................................................................17
Principle No. 4: Avoid Conflicts of Interest and the Appearance of Improper Influence .. 17
Conflicts of Interest ................................................................................................................17
Gifts and Entertainment .........................................................................................................18
Bribes and Kickbacks ............................................................................................................18
Principle No. 5: Consider the Potential for Misperception When Engaging in Political
Activities or with Public Officials ...........................................................................................19
Personal Political Activity .......................................................................................................19
Political Contributions ............................................................................................................19
Solo Cup Company
CODE OF BUSINESS CONDUCT
Page 4 of 19
September 2010
MAKE YOURSELF HEARD
How to speak up about potential violations: You have an obligation to promptly
raise a concern about a possible violation of the Code or the law. There are a number
of people in the Company who can provide you with answers to your questions or
address any concerns about what might be a Code violation or whether a violation
occurred.
You can and should discuss the issue or question with any of the following:
•
•
•
•
•
•
Your supervisor or manager
The next level of management, including your supervisor’s supervisor or the
head of your department or location
A member of the executive management team
Your local human resources representative
Solo Cup Company’s legal department
The Ethics Helpline at 1-866-294-9502, also available by clicking the “File a
Report” tab at www.ethicspoint.com
Although it is not required that you go to your supervisor or manager first, generally, he
or she will be in the best position to resolve the issue quickly and therefore should be
the starting point. However, if your supervisor or manager does not resolve the issue (or
is involved in the issue), you should raise it with one of the other contacts listed above.
Those who supervise others have additional responsibilities under the Code:
•
•
•
•
•
Explain to your employees why compliance with the Code is required
Encourage discussion of business standards and ethics
Monitor compliance of the people you supervise
Respond promptly and properly to concerns raised by your employees
Protect employees against reprisals when they raise ethical questions or
concerns or report actions they feel may have violated this Code
ETHICS HELPLINE
The Ethics Helpline is dedicated to receiving any reports you may have of a violation or
potential violation of our Code of Business Conduct. Solo Cup has selected EthicsPoint,
an independent third party, to provide you with a way to confidentially file a report either
through a website or a toll-free telephone number. You have the option of remaining
anonymous if you so choose. The toll-free telephone number for US/Canada is 1-866294-9502, and the website address is www.ethicspoint.com
For further information, including international phone numbers and the website, please
click on the Ethics Helpline link on Solo’s intranet available under the tab labeled “What
Guides Us”.
Solo Cup Company
CODE OF BUSINESS CONDUCT
Page 5 of 19
September 2010
GOVERNING PRINCIPLES
The following five principles should guide you while conducting company business to
ensure compliance with the Code:
Principle No. 1
Be fair and ethical when interacting with customers,
competitors and suppliers; in particular, comply with all
applicable laws.
Principle No. 2
Treat your co-workers with dignity and respect.
Principle No. 3
Provide accurate disclosure and protect Solo Cup’s
confidential and proprietary information.
Principle No. 4
Avoid conflicts of interest and the appearance of improper
influence.
Principle No. 5
Consider the potential for misperception when engaging
public officials or political activities.
You must adhere to these principles, as detailed below. You risk being disciplined or
terminated if you fail to comply with the Code and its guiding principles. In addition, you
may be personally liable if you break the law.
NOTE: For U.S. operations, many of the Principles are supported by more
specific company policies. When you see a reference number –for example,
1234 -- following a topic in this Code, please check the “Working at Solo” link on
the Channel ONE website to review the details of the supporting policy.
Solo Cup Company
CODE OF BUSINESS CONDUCT
Page 6 of 19
September 2010
PRINCIPLE NUMBER 1:
Competition Laws:
Fair competition laws, which
include U.S. Antitrust statutes,
are the body of laws prohibiting
anti-competitive behavior and
unfair business practices, such
as price-fixing and predatory
efforts to eliminate competition.
The purpose of competition
and antitrust laws is to
preserve
fair
and
open
competition in a free market
economy.
These laws are confusing at
times and can be counterintuitive.
All questions or
concerns about this area of law
should be directed to Solo Cup
Company’s legal department.
Be fair and ethical when interacting with customers,
competitors and suppliers; above all, apply with all
applicable laws.
In compliance with competition laws, as a Solo Cup employee,
you must never:
• Fix prices – this can include setting minimum or maximum
prices, or “stabilizing” prices.
• Fix terms related to price, pricing formulas, trade promotions
or credit terms.
• Divide up markets, customers or territories.
• Rig a competitive bidding process, including arranging to
submit falsified bids.
• Boycott a competitor, supplier, customer or distributor.
• Discuss competitive matters with any competitor—at any
time or any place.
• Establish exclusive dealing arrangements (e.g. contracts that
require a company to buy only from or sell only to a Solo Cup
company).
• Engage in activities involving trade associations or setting
industry standards.
• Monopolize or attempt to monopolize markets illegally, or
abuse a dominant position in the marketplace.
• Charge different prices to competitors in violation of laws such
as the Robinson-Patman Act.
Laws Relating to Foreign Operations:
Take time to understand and
adhere to all applicable
foreign laws, particularly
where your work takes place
outside of the United States.
To the extent that your activities involve operations
outside the United States, you may be subject to the
laws of foreign jurisdictions, instead of or in addition to
the laws of the United States, that affect such activities.
Since the Company is regulated by a number of
jurisdictions, it is important that you understand and
adhere to all applicable foreign and U.S. laws.
Solo Cup Company
CODE OF BUSINESS CONDUCT
Page 7 of 19
September 2010
Acquiring a Competitor’s Confidential
Information: It is always beneficial to
learn as much as possible about our NEVER use, or attempt to obtain, a
competitors, as well as our suppliers and competitor’s confidential or proprietary
our customers if such information is information.
generally available to the public.
However, we must be ethical about how
we acquire a competitor’s information,
and we must ensure our competitors do
not reasonably consider such information
to be confidential.
Trade Compliance: Import/Export Issues and Boycott
Laws: Every country has laws about importing and exporting
goods and technology. As Solo Cup employees, agents and
representatives, we must comply with all applicable import
and export controls. In particular, this means (1) complying
with all trade restrictions placed on sanctioned countries,
which apply to certain software and technologies as well as
our products; (2) paying all import duties, value added taxes
and excise taxes in relation to our products; and (3) refusing
to cooperate with any request concerning boycotts or related
restrictive trade practices.
You must comply with all
Government requirements and
all Company quality standards
for products that the Company
manufactures and / or sells. This
includes compliance with all
applicable laws and regulations
governing the manufacture and
distribution of our products.
Refer any
concerns or
questions
regarding a trade
issue to the
Legal
Department.
Product Quality and Regulatory Compliance:
Maintaining the high quality of Solo Cup’s products is
critical to our success. Quality is not just a
manufacturing plant responsibility: the quality of our
products starts with understanding the requirements of
our customers, defining those requirements, and
designing products to meet or exceed those
requirements. Our quality and service standards are
designed to ensure that our customers receive the right
products at the right time.
Solo Cup Company
CODE OF BUSINESS CONDUCT
Page 8 of 19
September 2010
When the Government is a Customer: Special rules apply when a Government is our
customer—rules that are in some cases very different than those that apply to
commercial customer transactions. Violations can result in civil or criminal penalties.
If you are involved in bidding on, or providing service under, a Government contract,
you must:
•
•
•
•
•
•
•
•
Never seek or accept confidential bid information.
Never offer or provide gifts, gratuities or entertainment without prior written
approval of your supervisor and the Legal Department.
Understand “most favored customer” pricing and verify compliance with the
Pricing or Legal Departments.
Conform strictly to the contract’s quantity, quality and testing requirements.
Ensure invoices are accurate, complete and in full compliance with all rules and
regulations.
Be truthful, accurate and complete in all representations and certifications.
Know the Government’s rules and regulations with respect to the bid and the
contracting processes.
Refrain from initiating any employment discussions with any current or former
Government employee unless you have first consulted with the Legal
Department.
Prohibition of Foreign Corrupt Practices: The laws of
virtually all countries in which Solo Cup operates, as well as
important extra-territorial laws, such as the U.S. Foreign
Corrupt Practices Act (“FCPA”) and similar laws, prohibit
bribes. Thus, when dealing with a government or public
official, we (1) always act with complete honesty and
transparency; and (2) never offer anything of value to
governmental authorities to obtain any improper advantage
in selling goods or representing the Company’s interests. A
violation of these principles could potentially be a serious
criminal offense for both the Company and for the individuals
involved, resulting in fines, loss of export privileges and even
imprisonment.
Always seek guidance
from the Legal
Department before
making payment of any
kind to a government or
public official.
Solo Cup Company
CODE OF BUSINESS CONDUCT
Page 9 of 19
September 2010
Supplier Relationships: Solo Cup bases
its relationships with suppliers on lawful,
•
efficient and fair practices. We also expect
our suppliers to adhere to applicable legal
requirements in their business relationships,
including those with their employees, their
local communities and their customers. Solo
Cup has adopted a Supplier Code of
•
Conduct which requires all Solo Cup
suppliers to adhere to a set of guidelines
outlined in that code. The quality of our
supplier relationships often has a direct
bearing on the quality of our customer •
relationships. Likewise, the quality of our
suppliers’ products and services affects the
quality of our own products.
Government Inquiries:
Solo Cup’s
business is regulated by a number of
government agencies, including the
Internal Revenue Service, Department of
Labor, the Securities and Exchange
Commission and the Federal Trade
Commission. Occasionally, a government
official may request information or make
an inquiry about our activities. When this
happens, Solo Cup cooperates with all
reasonable requests for information.
Provide competitive opportunities for
suppliers to earn a share of Solo
Cup’s purchasing volume, including
small businesses and businesses
owned by the disadvantaged,
minorities and women.
Enlist supplier support in ensuring
that Solo Cup consistently meets
and exceeds customer expectations
of quality, cost and delivery.
Do business only with suppliers who
comply with Solo Cup’s Supplier
Code of Conduct.
Never mislead or make false statements
during a government inquiry. Almost every
government agency makes it a crime to
knowingly submit false or incomplete
information; therefore, all information you
provide must be honest, accurate and
complete.
Always contact the Legal Department
before providing information as part of a
government inquiry.
Advertising and Promotion of Products: Solo Cup’s reputation is a critical
component of our success in maintaining our customers’ trust. To preserve our
reputation as a responsible supplier whose products and services are desired for their
features, innovation, quality and value, we must build trusting relationships through,
among other things, the honest and fair description of our products.
Ensure that all advertising and sales activities are accurate, fair and honest. Before
making a claim about a product, you must be able to substantiate it. All product-related
claims or endorsements must receive proper approval. This includes all types and
means of advertising, marketing, sales promotion and public relations, including use of
electronic media, social networks and blogs.
Solo Cup Company
CODE OF BUSINESS CONDUCT
Page 10 of 19
September 2010
Environmental Compliance: Solo Cup is committed
to protecting human health, natural resources, and the
environment in which we live and operate. We must
ensure our actions are in accordance with state and
federal environmental regulations, and promptly contact
the Legal Department if we have concerns regarding
Solo Cup’s environmental compliance. However, Solo
Cup’s commitment extends beyond compliance with
the law to include efforts to minimize the environmental
impact of its operations and products.
Privacy:
In our increasingly
information-based society, customer,
employee, medical, financial and
other sensitive personal information
must be adequately protected from
unauthorized disclosure. Solo Cup is
committed to protecting personal
information that it collects and
maintains, as well as to compliance
with all applicable privacy and data
protection laws, regulations and
treaties.
PRINCIPLE NUMBER 2:
Continuous improvement
through innovation to achieve
superior, environmentally
sound results is your
responsibility.
Guidelines in this area include:
• You must never seek access to personal
information if you do not have a legitimate
business reason.
• If you do have a legitimate reason to access
such information, use it for authorized
business purposes only; take steps to protect
it against any unauthorized release or use,
including keeping secure our paper and
computer-based records.
• Consult with the Legal Department before
establishing or updating any system, process
or procedure to collect, use, disclose or
transmit individual customer, employee or
vendor information, including medical or
financial records or other sensitive personal
information.
Treat your co-workers with dignity and respect.
Non-Discrimination and Diversity: Solo Cup does not discriminate and is committed
to its responsibility to extend employment opportunity to all individuals. We recruit, hire,
develop, promote, discipline and provide other conditions of employment without regard
to a person’s gender, race, color, religion, age, national origin, sexual orientation,
ancestry, veteran status, disability, citizenship, marital status, or any other legally
protected status. Solo Cup also takes affirmative action to employ and advance
minorities, females, individuals with disabilities and veterans. 1001
Solo Cup Company
CODE OF BUSINESS CONDUCT
Page 11 of 19
September 2010
Solo Cup does not tolerate
harassing behavior. If you
experience, witness or observe
conduct that you believe
constitutes workplace
harassment, you must report it.
Retaliation:
Solo Cup prohibits any form of
retaliation directed against an
employee who complains, in
good faith, about workplace
discrimination, harassment or
safety concerns, or an employee
who participates in investigations
of these types of issues. 1001
1002
Workplace Harassment: Solo Cup is committed
to providing a work environment free from
intimidating, hostile or offensive actions or
behavior to all employees. This type of behavior is
typically referred to as “harassment,” and it is
prohibited whether based on gender, race, color,
creed, religion, national origin, ancestry, marital
status, age, sexual orientation, veteran status,
disability or any legally protected basis.
Harassment based on gender can include
unwelcome sexual advances, requests for sexual
favors and other verbal or physical conduct of a
sexual nature. 1002
If you feel you have been coerced, intimidated or
threatened for reporting an incident of
discrimination or harassment or for assisting in an
investigation, you should discuss your concerns
with any of the following:
• Your supervisor or manager
• The next level of management, including
your supervisor’s supervisor or the head of
your department or location
• A member of the executive management
team
• Your local human resources representative
• The legal department
• The Ethics Helpline at 1-866-294-9502,
also available by clicking the “File a Report”
tab at www.ethicspoint.com
Alcohol and Drug Free Workplace: Solo Cup is
committed to providing a safe, healthy and
productive work environment for employees. In
particular, Solo Cup is concerned about alcohol or
substance abuse and/or the presence of alcohol or
illegal substances on Solo Cup property because
such activity can have a serious adverse effect on
safety, attendance, productivity and product quality.
Solo Cup employees have the right to be free from
the safety risks and work-related problems caused
by drug or alcohol abuse. 1004
You are prohibited from using or
possessing any alcohol, illegal
drug or controlled substance, or
any un-prescribed medication,
on Company property or while
engaged in Company business.
The prohibition applies at all
times, including breaks.
Solo Cup Company
CODE OF BUSINESS CONDUCT
Page 12 of 19
September 2010
Your work location has safety rules that you
must follow at all times. In addition, you must
comply with all applicable environmental,
health and safety laws and regulations
(including international safety rules where
applicable).
Environment, Health and Safety:
Solo Cup is committed to providing its
employees with a safe and secure work
environment. Safety is particularly
important in manufacturing locations,
which are subject to significant
workplace safety regulations.
Minimum Hiring Age/Child Labor: Solo Cup does not produce or manufacture
products using forced or indentured child labor. Regular, full-time employees at Solo
Cup are at least 18 years of age. In some instances, part-time work, summer jobs, or
apprenticeship programs may exist for younger individuals as part of a regulated or
supervised program that balances the person’s educational and social development.
Employee Privacy: Solo Cup keeps all former employee and current employee
information (“Employee Information”) confidential. Solo Cup is committed to preventing
disclosure of Employee Information to third parties, and requires its employees to
provide written authorization to release Employee Information to a third party. This
requirement does not apply to government agencies or certain third parties with which
Solo Cup has contracted to administer company sponsored benefits. Solo Cup
complies fully with federal Health Insurance Portability and Accountability Act (“HIPAA”)
regulations and requirements.
PRINCIPLE NUMBER 3: Provide accurate disclosure and protect Solo
Cup’s confidential and proprietary information.
Accurate Books and Records, Including Financial Disclosure: Accurate business
records are crucial. Solo Cup is required by financial disclosure laws, including
securities laws, to conform with applicable national or international accounting
standards and to maintain books and records that accurately and fairly reflect all
transactions.
Solo Cup is committed to providing full, accurate, timely and
understandable information about the Company in all material respects, and in
particular, with regard to its financial condition and results of operations.
Solo Cup Company
CODE OF BUSINESS CONDUCT
Page 13 of 19
September 2010
We help Solo Cup in meeting
this commitment by scrupulously
maintaining business records,
such as costs, sales, shipments,
time sheets, rebate information,
bills, payroll and benefits
records.
With respect to maintaining accurate business
records, follow these guidelines:
•
•
Senior financial officers and
other managers responsible for •
accurate books and records,
and accounting and disclosure
of financial information, have a •
heightened duty to ensure that
these standards are met.
•
Never deliberately make a false or misleading
entry in a report or record.
Never alter or destroy Company records except
as authorized by established Company record
retention policies.
Follow all laws, external accounting requirements
and Company procedures for reporting financial
and other business information.
Never hide or fail to record any funds, assets or
transactions.
Cooperate fully with any internal or external audit.
Use of Company Assets: We are each responsible for protecting our Company’s
assets, which includes ensuring their efficient use. Company assets include buildings
and property, equipment, vehicles, computers, software, office furniture, machinery and
supplies, confidential and proprietary information, and intellectual property. All company
assets belong to Solo Cup and must be used for legitimate business purposes only,
unless specifically approved by management. Be mindful of your own use of resources
and remind others to do the same.
Confidential information, including Proprietary
Information and Trade Secrets: “Confidential” or
“proprietary” information is a valuable asset. It
includes facts, data, ideas, strategies and knowledge
that have not been disclosed to the public.
Confidential information that has commercial value to
competitors or to others who have an interest in doing
business with Solo Cup is also referred to as a “trade
secret.”
Some examples of confidential information,
proprietary information and trade secrets (collectively
referred to as “confidential information”) include, but
are not limited to:
•
•
•
Customer lists, pricing and related information
Supplier lists and pricing
Marketing strategies and plans
You must protect confidential
information and ensure outside
parties do not gain access to it,
except as required by law.
Additionally, you may not
disclose confidential information
to others unless necessary to
carry out legitimate Solo Cup
business. Your obligation
continues even after you leave
Solo Cup, at which time you
must return all documents,
electronic records, computer
disks or anything else on which
confidential information may
have been stored, recorded or
otherwise memorialized.
Solo Cup Company
CODE OF BUSINESS CONDUCT
Page 14 of 19
September 2010
•
•
•
•
•
•
•
•
•
•
Vendor identities
Manufacturing methods, techniques, processes, forecasts or failures
Plant layouts
Standard Operating Procedures
Planned acquisitions or divestitures
Designs, prototypes, inventions, or programs
Research and development data
Pricing, costs, budget forecasts, and profit margins
Employment, wage and salary data
Personnel files and medical records
Patents, Trademarks and Copyrights: Solo Cup has developed procedures to
establish, protect, maintain and defend its rights in all of its intellectual property,
including patents, trademarks, copyrights and other intellectual property.
You must use Solo Cup’s intellectual property only in a way consistent with the law.
Furthermore, respect the intellectual property rights of others. Theft or misappropriation
of trade secrets, proprietary information, or other intellectual property may result in
significant fines and criminal penalties for you or Solo Cup.
In addition, you must promptly disclose to Solo Cup new inventions and ideas that you
develop while working for Solo Cup that relate in any way to the business of Solo Cup,
including any discoveries, inventions, improvements or works (including, without
limitation, computer programs, manuscripts, reports or formulas), whether relating to a
machine, apparatus, device, process, composition, product, article or other thing. Your
duty to disclose is not dependent on whether your invention, discovery, etc. was
developed directly in connection with your work duties or whether you designed or
developed the invention or idea while at home.
You should understand that the right, title and interest in inventions or ideas described
above belong to Solo Cup. It becomes Solo Cup’s intellectual property, and you should
regard and treat it as confidential. If asked, you will be expected to execute all
assignments and other documents that Solo Cup deems necessary to establish its right,
title and interest in these types of inventions and ideas referenced above.
Duty of Loyalty and Post-Employment Duties Not to Engage in Unfair Competition
or Solicitation: Through our employment with Solo Cup, we may have access to, learn
about, and / or help develop confidential information. This knowledge may enable us to
compete unfairly with Solo Cup during and after our employment.
Solo Cup Company
CODE OF BUSINESS CONDUCT
Page 15 of 19
September 2010
Consequently, in order to further protect Solo Cup’s confidential information:
1.
You have a duty of loyalty and good faith to Solo Cup during your employment
with Solo Cup. This duty requires, among other things, that you do not directly or
indirectly engage in, own, or assist any business which directly competes with
Solo Cup.
2.
If, while employed at Solo Cup, you engage in selling its products, are in contact
with Solo Cup’s customers or are exposed to Solo Cup’s confidential information,
you will not directly or indirectly perform the same or similar service
provided to Solo Cup for a business which directly competes with Solo
Cup for a period of one year after your employment with Solo Cup ends, for
any reason. Similar work means duties or tasks of the same or similar type as
the duties or tasks performed for Solo Cup during your employment with the
Company.
3.
For a period of one year after your employment ends, for any reason, you will not
directly or indirectly (which includes, but is not limited to providing employee
information to another) solicit any Solo Cup employee with whom you had
contact while at Solo Cup to end his or her employment relationship with Solo
Cup.
Electronic Media Use and Do not use Solo Cup’s electronic media to:
Network Security: Solo Cup’s
• Engage in electronic communications that might
assets include its electronic
be considered offensive, derogatory, defamatory,
media, such as e-mail, voicemail,
harassing, obscene or otherwise, vulgar.
intranet, internet, video and audio
• Improperly disseminate copyrighted or licensed
equipment, instant messaging,
materials or proprietary information or download
telephones,
cellular phones,
copyrighted information of others.
hardware, software, networks
• Transmit chain letters, advertisements or
and the information contained on
solicitations.
them. Remember, we must limit
• Visit inappropriate Internet sites.
our primary use of electronic
• Advance interests adverse to the Company.
media to legitimate business
• Run software programs not authorized by Solo
purposes.
Any personal use
Cup for legitimate business purposes.
must be legal, reasonable and
• Promote personal business ventures.
kept to a minimum. Information
must be protected through the
use of passwords and encryption
technology. 4001
Solo Cup Company
CODE OF BUSINESS CONDUCT
Page 16 of 19
September 2010
When using electronic media to express personal
opinions about Solo Cup and/or its employees and
representatives, you must:
•
•
•
Be courteous and thoughtful about how other
employees may be affected by postings.
Refrain from posting inaccurate, incomplete,
inappropriate, threatening, obscene,
defamatory, libelous, profane, embarrassing or
harassing comments about other employees
and / or representatives that may be harmful or
damaging to employee relationships.
Avoid personal attacks on other employees,
company representatives, management or
customers.
Personal Electronic Media Use:
Solo Cup fully supports open and
candid communication. However,
unnecessary
and
disrespectful
postings about Solo Cup employees
and/or the company undermine this
commitment and create a hostile
work environment.
Remember that a productive work environment is sustained by trust, honesty and
fairness, and we must always think about the effect our communications may have on
that environment.
Social Media: The same high standards of trust, honesty and fairness apply to the use
of Social Media networks. Social Media includes, but is not limited to: blogs, discussion
forums (such as chat rooms or message boards), newsgroups, e-mail distribution lists,
Myspace, Facebook and Twitter. 6007
In using Social Media, you must:
•
•
•
•
•
•
Disclose your employment or association with Solo Cup when commenting on
Solo Cup, its products, customers or competitors.
Explain that comments expressed about Solo Cup, its products, customers or
competitors are your personal opinions and not those of Solo Cup.
Prior to speaking on behalf of Solo Cup via Social Media, obtain approval from
an executive management team member.
Promote protection of customer privacy and request specific permission to
disclose any customer information.
Direct all media inquiries to our Director of Communications.
Protect all Confidential or Proprietary Information, or Trade Secrets (as described
above).
Solo Cup Company
CODE OF BUSINESS CONDUCT
Page 17 of 19
September 2010
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Refrain from knowingly communicating information that is untrue or deceptive.
All communications must be based on current, complete and accurate
information.
Refrain from conduct that is illegal or contrary to any Solo Cup corporate policy.
Avoid allowing Social Networking to interfere with your work duties or
responsibilities.
Respect your audience. Do not harass, threaten, defame, libel, or discriminate
against customers, competitors, fellow employees or anyone else.
We are each personally responsible for any content we publish through Social Media.
This includes liability for criminal or civil proceedings.
Records Management and Storage: Many of the documents that we handle or
produce, including email correspondence, are considered business records. These
must be retained for a particular amount of time, depending on the laws of particular
jurisdictions. For U.S. operations, information regarding what constitutes a Record and
how long a particular Record must be retained can be found in the Record Retention
Schedules, available through the Records Management Policy. Save business records
only for the time period specified in the Record Retention Schedules or in accordance
with the laws of your jurisdiction. 4003
PRINCIPLE NUMBER 4:
Avoid conflicts of interest and the appearance of
improper influence.
Conflicts of interest: A conflict of interest arises when our personal interests or
activities influence, or appear to influence, our ability to make business decisions in
Solo Cup’s best interest.
Some situations that could cause a conflict of interest
include:
We must avoid entering into
• Outside employment or affiliations.
relationships or arrangements
• Jobs and affiliations of close relatives.
that conflict with our duties
• Serving as a director of another business.
and obligations to Solo Cup.
• Having a significant financial interest in an existing or
potential competitor, a customer or a supplier.
Solo Cup Company
CODE OF BUSINESS CONDUCT
Page 18 of 19
September 2010
When evaluating whether you are entering into a situation that could potentially be a
conflict of interest, use good judgment and ask yourself:
• Would this investment/affiliation/activity affect any decisions I will make for Solo
Cup?
• How would this investment/affiliation/activity seem to others inside Solo Cup?
Would my co-workers think it might affect how I do my job for the Company?
• How would it look to someone outside, such as a customer, supplier or even the
media?
If you think you may have a conflict of interest, or that others could possibly believe an
activity or relationship in which you are engaged is a conflict of interest, please seek
guidance from and report the circumstances to a direct supervisor, the Ethics Helpline
or the Legal Department.
Gifts and Entertainment:
Neither we nor any member
of our immediate family may
accept lavish gifts from a
customer, supplier, or anyone
attempting to develop a
business relationship with
Solo Cup. This is an area in
which the exercise of our best
judgment is critical.
7003
You may accept modest gifts. These can include
occasional meals with a business associate, tickets to
ordinary sports, theatre and other cultural events, or
other reasonable and customary gifts and
entertainment. While it is impractical to establish a
dollar value that would cover every circumstance, a
good rule of thumb is that the aggregate market value
of a gift should not exceed $250.
If you accept a modest gift, you should not feel
obligated or expected to provide the giver special
treatment in the future.
There is one definite rule concerning gifts: You may
not accept gifts of cash or cash equivalents (such as a
debit card with cash already loaded) or, in most
circumstances, gift certificates.
Appearances can play a role when it
comes to gifts. Even if we believe that
giving or accepting a gift is appropriate,
it may be that our colleagues would
question our judgment.
You need to feel entirely comfortable giving or
accepting a gift. If you don’t, you should ask
your supervisor or the Legal Department for
advice.
If you have questions or concerns about gifts and entertainment policies, contact your
direct supervisor, local Human Resources representative, or the Legal Department.
Bribes and Kickbacks:
Do not give them.
Do not accept them.
Solo Cup Company
CODE OF BUSINESS CONDUCT
Page 19 of 19
September 2010
PRINCIPLE NUMBER 5:
Consider the Potential for Misperception When
Engaging in Political Activities or with Public
Officials.
Personal political activity: Solo
Cup recognizes that good citizens
are actively involved in public
affairs. Personal political activity
might include: supporting and
contributing to candidates and
political
parties;
seeking
public/elected office; volunteering
personal time to another’s political
campaign; or contacting an
elected official on an issue of
personal importance.
Political contributions: Every
country
has
different
laws
regarding involvement in the
political process. For example, the
U.S. and certain other countries
set strict limits on contributions by
corporations to political parties
and candidates, and violators are
subject to very serious penalties.
Your responsibility…
If you are involved in political activities, you must
always make it clear that your views and actions are
your own, and not those of Solo Cup’s or made on
behalf of the company. In addition, you may not use
company time, property or equipment for personal
political activities.
Laws governing political contributions are complex
and vary in each state and country. While certain
jurisdictions permit political contributions by
corporations, you may not make any direct or
indirect political contribution or expenditures on
behalf of Solo Cup unless authorized by the Legal
Department in writing. In most cases, political
contributions or expenditures also require the prior
written approval of Solo Cup Company’s Chief
Executive Officer.
This includes activities such as using company
funds to buy tickets for a political fund-raising event;
lending personnel during working hours for a fundraising activity; or paying for advertisements and
other campaign expenses.
Solo Cup Company