Evergreen Packaging Inc., including its subsidiaries and affiliates (“Evergreen Packaging”), is committed to doing business in a legal, ethical and socially responsible manner. Reflecting this commitment, all directors, officers and employees are expected to comply with the Evergreen Packaging Code of Business Ethics and Code of Conduct (“Evergreen Packaging Code of Conduct”) in conducting their business relationships. To maintain these standards, Evergreen Packaging desires to do business with those Suppliers whose practices are consistent with Evergreen Packaging’s ethics and principles of business conduct. This Supplier Code of Conduct, as amended or modified from time to time (the “Code”) sets forth the types of standards and practices that Evergreen Packaging expects of its Suppliers.
Suppliers are expected to abide by all applicable laws and regulations (including, but not limited to, the Foreign Corrupt Practices Act) applicable to it and to the Supplier’s relationship with Evergreen Packaging. These include laws regarding anti-corruption, anti-bribery, environmental matters, occupational health and safety, labor and employment practices, human rights, immigration, product safety, shipping and product labeling. Evergreen Packaging also expects that its Suppliers will comply with applicable guidelines and best practices for their industry. In the event there is any conflict with industry practice and applicable law, the higher standard will take precedence.
The Evergreen Packaging Code of Business Conduct restricts Evergreen Packaging employees from accepting gifts or favors from suppliers or prospective suppliers, and from using their status with Evergreen Packaging in order to obtain personal gain from those wishing to do business with Evergreen Packaging. There are limited exceptions to these restrictions for gifts of nominal value and customary hospitality or entertainment. We ask that our Suppliers do not place our employees in the difficult position of having to refuse gifts or favors that would conflict with the Evergreen Packaging Code of Conduct. Suppliers must not offer or provide gifts, entertainment, hospitality or favors to Evergreen Packaging employees to obtain favorable treatment from such Evergreen Packaging employees. However, gifts of nominal value, entertainment or hospitality may be offered or provided which are customary and proper in the circumstances, provided that no obligation could be, or be perceived to be, expected in connection with the gift, entertainment or hospitality.
Evergreen Packaging expects its Suppliers to conduct their businesses in a manner that preserves and protects the environment. To minimize or eliminate negative impacts of their operations on the environment, Suppliers should endeavor to minimize waste, avoid excess packaging, use sustainable, nontoxic, recycled and recyclable materials where possible and promote energy efficiency. Suppliers that provide animal products should ensure that animals are treated in accordance with government and industry-accepted guidelines for humane treatment.
Suppliers shall not use workers under the applicable legal age of employment or forced involuntary labor or engage any supplier, vendor, contractor or partner that uses such workers. Suppliers should only use workers who are not less than sixteen (16) years of age. Where local standards are higher, no person under the legal minimum working age will be employed by Supplier. Suppliers shall ensure that none of its operations engages in human trafficking, does not hold passports of its employees, does not detain or prevent employees from leaving employment or the workplace or use force, fraud or coercion in maintaining its workforce.
Suppliers shall ensure that all of its workers, whether employees or contractors, are properly documented and legally qualified to work in the jurisdiction where such workers are providing services as required under local immigration, tax, and other related laws.
The procedures and policies of Suppliers should reflect the commitment of Evergreen Packaging to fair and reasonable labor and employment practices as well as diversity in the workplace. Suppliers are expected to comply with all local and applicable labor laws and employment standards, such as compensating workers in compliance with all applicable wage, benefit and employment standards laws and maintaining reasonable employee work hours and a safe and healthy workplace. Suppliers are also expected to take reasonable efforts to promote and achieve diversity in the workplace. Evergreen Packaging expects that Suppliers shall not inflict, threaten to inflict or permit corporal punishment or any other forms of physical, sexual, psychological or verbal abuse or harassment on any employees.
Supplier shall identify, evaluate and manage occupational health and safety hazards through a prioritized process of hazard elimination, engineering and administrative controls. Supplier shall provide workers with appropriately maintained job-related protective equipment, and provide instructions and training on its proper use.
Supplier shall identify and assess potential emergency situations and develop and implement emergency plans and response procedures that minimize harm to life, environment and property.
Evergreen Packaging employs best practices for storage and distribution of food packaging products. The procedures of Evergreen Packaging Suppliers for materials used in food contact packaging in regard to food safety, packaging and distribution should meet or exceed industry standards. All Suppliers, for both food and general merchandise products, should also meet or exceed standards for product safety applicable in their industry, including those established by applicable regulators and consumer standards associations. The safety of products provided by Suppliers should also be protected by adequate security measures at all stages of production, packaging, storage and distribution in order to prevent tampering or contamination.
All products provided by Suppliers must be safe for their intended purpose, as applicable, by Evergreen Packaging customers. Each Supplier is expected to have in place proper procedures to identify potentially harmful products and complete an appropriate product recall, whether voluntary or mandated, in accordance with applicable laws and industry practices. Such procedures should ensure clear and prompt communication regarding such products to consumers and Evergreen Packaging and the immediate removal of potentially harmful products from Evergreen Packaging inventory.
Suppliers may from time to time be provided with or have access to confidential business information, trade secrets, formulations, recipes, specifications or other sensitive information which belongs to Evergreen Packaging. Suppliers must keep all such information strictly confidential and shall only disclose it to those individuals within their own organizations with a need to have the information. Suppliers shall not disclose such information to any other party without the written permission of Evergreen Packaging.
This Code applies to all Evergreen Packaging Suppliers and should not be read in lieu of but in addition to the Supplier’s obligations as set out in any agreements between Evergreen Packaging and/or its affiliates and the Supplier. In the event of a conflict between this Code of Conduct and an applicable agreement, the agreement shall govern. In addition, Suppliers shall ensure that all suppliers and subcontractors used by a Supplier to provide goods or services directly or indirectly to Evergreen Packaging also respect this Code. Evergreen Packaging reserves the right to take appropriate remedial action in the event a Supplier violates the Code.
In the event that any Supplier becomes aware of any violation or potential violation of this policy, the Supplier should notify the Evergreen Packaging account representative or the Evergreen Packaging Law Department by filing a report here.
At Evergreen Packaging’s request, Suppliers are expected to certify their compliance with this Code of Conduct.
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