Code of Business Ethics


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.


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



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.


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.

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 non-U.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.


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.


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.


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.


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
  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
  7. 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.


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.


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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