INTRODUCTION

This statement is made by ProAmpac UK Limited (“ProAmpac UK”) on behalf of its UK Group (defined below) in accordance with Section 54 of the Modern Slavery Act 2015. It covers the steps taken by the UK Group during the Financial Year 2024 and has been approved by the ProAmpac UK board of directors.

OUR BUSINESS AND STRUCTURE

We are part of ProAmpac Holdings Inc., a leading global flexible packaging company with comprehensive product offerings, providing creative packaging solutions, industry-leading

The UK Group has over 500 employees and operates in six locations in England.

ProAmpac UK has its registered office at Highdown House, Yeoman Way, Worthing, West Sussex. There are six subsidiaries in this group, all based in the UK (together with ProAmpac UK, the UK Group):-

• ProAmpac London Limited
• ProAmpac Security Products Limited
• ProAmpac Elsham Limited
• ProAmpac Lincoln Limited
• ProAmpac Grimsby Limited
• ProAmpac Lincoln Limited

OUR SUPPLY CHAINS

Our supply chains throughout the UK Group are both global and national in scope. We attempt to build long lasting relationships with our suppliers, and we have been working with some of our suppliers for over 20 years. While we do outsource certain administrative functions to other companies, these outsourced companies are all based within the UK.

We have considered the risk of modern slavery in our own operations, and we have concluded that, on the basis that we are a UK employer subject to UK employment protections and practices and already have well developed checks and balances within our business, we have a very low risk of modern slavery occurring in our own operations.

Suppliers are strongly encouraged to commit and adhere to our standards, which include a requirement to abide by the Ethical Trading Initiative base code.

We have considered the risk of modern slavery occurring in our use of employment agencies for permanent placements on site. Given the organisations that we work with and the existing checks that we apply in these areas, we have concluded that the risks of modern slavery are low in this area.

OUR POLICIES

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any other part of our business. Across our UK Group we have policies dedicated to combatting this, including policies around Human Rights and Ethical Trading, Social Compliance, Modern Slavery and Human Trafficking, Health and Safety and Anti-discrimination. These policies reflect our commitment to acting ethically and with integrity in all of our business relationships and implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our business or supply chains.

Across our group we rarely use agency labour, and where it is used it is used only within our recruitment process for permanent positions, and we ensure these are from reputable agencies who comply with our Ethical Trading policies.

DUE DILIGENCE

As part of our initiative to identify and mitigate risk we use a 3rd party tool to verify new suppliers to confirm that they have in place sufficient processes to ensure ethical trading, such as their own strict codes of conduct addressing these subjects.

SUPPLIER ADHERENCE TO OUR VALUES AND ETHICS

We have zero tolerance for slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we have in place an approved supplier system. Where we identify that a supplier is not compliant with these requirements, our policy is to take appropriate measures to encourage and persuade them to adopt suitable measures, and ultimately reserve the right to terminate relationships with any suppliers who will not comply.

TRAINING

Employees at our UK sites, who have direct responsibility for supply chain management are required to review the Code of Conduct on an annual basis, including updates and discussions of child labour laws, human trafficking, and forced labour.

Our employees are made fully aware of all our policies on induction and are required to avoid any activity that might lead to, or suggest, a breach of this or any internal policy. Employees are encouraged to raise concerns to their Line manager about any issue or suspicion of modem slavery in any part of our organisation or supply chain.

OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING

We do not currently have in place a formal system of key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains. We have, to date, not identified or been made aware of any instances of slavery or human trafficking taking place in our business or supply chain, and we are confident that the processes and procedures we have put in place are sufficient to ensure that we would identify any that occurred. This notwithstanding, we will continue to consider whether any formal KPIs will be appropriate to include in the future.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the ProAmpac UK Limited slavery and human trafficking statement for the financial year ending December 31, 2023. It was approved by the board on September 11, 2024.

PROAMPAC UK LIMITED

Date: September 11, 2024