ProAmpac is committed to ensuring that working conditions in its supply chain are safe, that workers are treated with respect and dignity, and that processes are environmentally responsible. This code of conduct applies to all businesses that provide products or services for ProAmpac and its subsidiaries, divisions, or affiliates. ProAmpac suppliers must comply with the laws, rules, regulations, and ProAmpac policies of the countries and locations in which they operate. They are expected to be familiar with the business practices of their suppliers and subcontractors, and ensure they operate according to this code of conduct. ProAmpac requires suppliers to commit to this code of conduct as a condition of doing business; ProAmpac may discontinue its relationship with suppliers who fail to comply with this code.

Labor and Human Rights:

Child Labor:

Child labor is strictly prohibited, and suppliers must comply with all local laws regarding labor and employment requirements. In the absence of local law, suppliers may not employ workers under the age of 15 (or 14 where allowed by local law). Workers under the age of 18 may not perform work likely to jeopardize their health, safety, morals or education.

Forced Labor:

Suppliers must not participate in human trafficking; used forced, involuntary, or slave labor; or purchase materials or services from companies using forced, involuntary, or slave labor. They must be able to certify that materials included in their products comply with the slavery and human trafficking laws of the country or countries in which they do business.

Hiring and Employment practices

Suppliers’ hiring practices must include verification of workers’ legal right to work in the country and ensure that all mandatory documents, such as work permits, are available. ProAmpac suppliers are expected to support diversity and equal opportunity in their workplaces. Suppliers must also prohibit discrimination based on race, color, gender, nationality, age, disability, union membership, maternity, sexual orientation or marital status.

Harassment

ProAmpac suppliers must treat all workers with respect and dignity. They may not subject workers to corporal punishment, physical, sexual, psychological, or verbal harassment or abuse. Supplier may not use monetary fines or withhold base compensation as a way to discipline employees.

In addition, suppliers must provide an environment that allows employees to raise concerns without fear of retaliation. Where it is allowed by law, suppliers should have a system that allows employees to anonymously report their concerns.

Compensation and Working Hours

Suppliers must comply with the applicable wage and hour labor laws and regulations governing employee compensation and working hours. Suppliers should conduct operations in ways that limit overtime to a level that ensures a humane and productive work environment.

Health and Safety

Conditions

ProAmpac suppliers must provide workers a clean, safe and healthy work environment in compliance with all legally mandated standards for workplace health and safety in the areas that they operate. This includes any residential facilities that suppliers provide for their workers.

Environment

Suppliers are expected to conduct their operations in a way that minimizes the impact on natural resources and protects the environment, customers, and employees. They must ensure their operations comply with all laws related to air emissions, water discharges, toxic substance, and hazardous waste disposal.

Ethics

Improper Payments

Bribes, kickbacks, and similar payments are strictly prohibited. This ban applies even when local laws may permit such activity. Employees, suppliers, and agents acting on behalf of ProAmpac are strictly prohibited from accepting such considerations under any circumstances.

Confidential Information

Proper management of confidential information is critical to the success of both ProAmpac and suppliers. Suppliers must protect all ProAmpac information, electronic data, and intellectual property with appropriate safeguards. Any transfer of confidential information must be executed in a way that secures and protects the intellectual property rights of ProAmpac and its suppliers. Suppliers may receive our confidential information only as authorized by a confidentiality or non-disclosure agreement and must comply with their obligations to not disclose the confidential information, to not use the information except as permitted by the agreement, and to protect the information form misuse or unauthorized disclosure. Our suppliers can similarly expect ProAmpac to safeguard their confidential information. Suppliers may not use the ProAmpac trademark, images, or other materials to which ProAmpac owns the copyright, unless explicitly authorized.

Supplier Management System

Suppliers are expected to have a management system that ensures they comply with applicable laws, regulations, and ProAmpac policies; conform to the Supplier Code of Conduct; and identify and reduce operational risks related to this code. The system should also promote continuous improvement and compliance with changing laws and regulations. An environmental management system is strongly recommended for environmental compliance.

Supply Chain Transparency

Supply chain transparency is required to confirm compliance to this code of conduct. To monitor this, ProAmpac may request documentation, conduct onsite audits, review and approve corrective action plans, and verify implementation of corrective actions.

Communication

Suppliers are expected to assist ProAmpac in enforcing this Supplier Code of Conduct by communicating its principles to their managers, employees, and suppliers.

Any supplier may direct questions or comments about this code of conduct to his/her supply chain contact within ProAmpac.

Supplier Acknowledgement

The undersigned supplier hereby acknowledges that it has received the ProAmpac Code of Conduct for Suppliers and agrees to comply with its terms and conditions. Supplier further acknowledges that failure to comply with any requirement of the Code of Conduct for Suppliers may result in cancellation of existing orders and termination of its business relationship with ProAmpac. Supplier also understands that its agreement to comply with the Code of Conduct does not obligate ProAmpac to conduct business or place any orders with the supplier.

Signature:___________________________________________________

Printed Name: _______________________________________________

Job Title: ____________________________________________________

Company: ___________________________________________________

Date:________________________________________________________