Supplier Responsibilities

Code of Conduct

In line with our mission and as part of our continuous improvement culture, we have developed the Silgan Specialty Packaging Supplier Code of Conduct to ensure that all our suppliers adhere strictly to all applicable laws and regulations in the areas in which they operate, and all respect and uphold our commitments to ethical business practices, fair dealing, human rights, worker safety and protection of the environment. Our expectations of our suppliers are designed to meet the following principles:

Ethics: suppliers must conduct their business in the most ethical manner and with integrity.

Any form of bribery is prohibited.
Suppliers should not engage in any unfair and anti-competitive practices.
Suppliers must ensure business decisions are made in the best interest of the business and avoid any conflict
of interest.
Suppliers are obligated to protect the rights and confidential information of the business.
Data Privacy and Data Protection -suppliers must comply with applicable laws and regulations related to
the collection, transfer, processing, and retention of personal information.

People and Labor: suppliers must protect employees’ human rights, prohibit any form of discrimination or harassment against any individual, and provide a safe and healthy working environment for workers. All employees must be treated with dignity and respect.

Child labor and forced labor are prohibited in any form.
Suppliers must ensure safe working conditions for all employees.
Suppliers are required to pay fair wages and provide fair working conditions.
Suppliers will guarantee an inclusive and diverse working environment.

Quality: The Supplier is in full compliance with quality specifications and maintains industry standards and certifications for testing and audits. In addition, Supplier shall implement necessary quality control measures throughout the entire supply chain and ensure the security and integrity of products and services.

Governance and Management Systems: suppliers must have control systems in place to meet all requirements and promote continuous improvement in their supply chain.

Supplier is in full compliance with all applicable international and domestic laws and regulations.
Supplier is committed to following the principles of this Supplier Code of Conduct and operating with
business integrity under all circumstances.
Supplier shall promote ethical, sustainable, and responsible operations and minimize the environmental
impact of new and existing products and services.
Supplier shall implement appropriate plans to reduce risks in all areas across the operations and enhance
supply chain resilience.
Supplier is committed to continuous improvement.
Supplier shall maintain business-related documents and grant Silgan Specialty Packaging the right to audit.

Certification of Compliance: By acceptance of any purchase order from Silgan Plastics or the provision of any goods or services purchased by Silgan Specialty Packaging, the Supplier acknowledges acceptance of this Supplier Code of Conduct and agrees to comply with all the requirements in this document.

Sustainable Procurement Policy

Our Commitment:

Silgan Specialty Packaging (SSP) conducts its business in a way that makes us proud and should make our stakeholders proud. We depend on our suppliers to support our business, and we expect and require our suppliers to adhere strictly to all applicable laws and regulations in the areas in which they operate and that they respect and uphold our commitments to ethical business practices, fair dealing, human rights, worker safety and protection of the environment.

Objective and Scope:

This Sustainable Procurement Policy (The Policy) applies to all global Silgan Specialty Packaging team members and all suppliers supporting Silgan Specialty Packaging operations. We expect all our global operations to adhere to this policy as a core principle in their local procurement strategies and practices. The expectation is for all locations to view this Policy as a minimum requirement to manage their operations. Local policies on sustainable procurement must be shared with and approved by the Procurement and Supply Chain Optimization department.

This Policy shall be shared with relevant stakeholders.

Ownership and Review:

This Policy shall be owned and maintained by the Procurement and Supply Chain Optimization department, in consultation with the CFO/VP of Finance, Director of HR, Director of Quality, Director of Operations and Operational Excellence, and the Sustainability Projects Coordinator. The Policy and its implementation shall be reviewed annually to ensure continuous improvement. In addition, this Policy will be distributed annually to internal stakeholders for acknowledgment.

Policy:

I. Supplier Selection and Qualification

Meeting our commitments to sustainable procurement requires that we identify, evaluate, and select our suppliers based on their ability to adhere to our core principles and hold suppliers accountable for meeting our minimum requirements as outlined in this Policy. We have established the following requirements to help us select the right suppliers for our business:

a. New Suppliers

Complete New Supplier Questionnaire and Supplier Compliance Questionnaire
Complete Supplier Risk Assessment Questionnaire
Acknowledgment of Silgan Specialty Packaging Supplier Code of Conduct
Follow supplier selection and qualification guidelines established by the Silgan Specialty Packaging Quality
department

b. Existing Suppliers

Ensure that 100% of strategic suppliers complete a Supplier Compliance Questionnaire
and Risk Assessment Questionnaire by December 31, 2022
Ensure that 100% of strategic suppliers acknowledge the Silgan Specialty Packaging Supplier Code of
Conduct by August 1, 2022
Integrate the Silgan Specialty Packaging Supplier Code of Conduct into 100% of purchase orders by
December 31, 2022
Ensure that 100% of our raw materials suppliers are compliant with our Silgan Specialty Packaging
product stewardship requirements applicable to their products, including but not
limited to compliance with the appropriate internationally recognized standard for their
product
Publicize the Silgan Specialty Packaging Supplier Code of Conduct on the Silgan Specialty Packaging website by
December 31, 2023

II. Supplier Evaluation

We believe that regular monitoring of our suppliers’ sustainability and compliance practices is essential to meeting our sustainable procurement objectives.

We have established the following objectives to help us evaluate our suppliers:

Distribute Silgan Specialty Packaging Supplier Code of Conduct, Sustainable Procurement Policy, and
Data Protection Agreement to 100% of strategic suppliers on an annual basis
Conduct annual Supplier Performance Evaluation and Sustainability Assessment of our
strategic suppliers in major purchasing categories
Complete Risk Assessment of 100% of strategic suppliers on an annual basis
Create metrics to identify non-compliant suppliers and create a process to address and
remediate the non-compliance
If applicable, validate certifications on ETQ (ISO, GFSI) are up-to-date

III. Policy Publication, Management, and Monitoring

This Silgan Specialty Packaging Sustainable Procurement Policy will be published and communicated internally
to all stakeholders.

We are committed to acting with due diligence to prevent any violation of our Supplier Code of Conduct, understanding due diligence to be a continuous process through which we identify, mitigate and respond to issues as they may arise across our global operations and within our global network of suppliers and business partners.

To verify that measures are being taken to comply with this Policy across our supply chain, we regularly assess whether the organization’s activities and relationships have any real or potential impact on our people, products, our environment, or the communities in which we operate. We integrate these commitments and assessments into our in-house systems for monitoring and reporting on performance.

IV. Enforcement

All Silgan Specialty Packaging operations and team members are expected to fully comply with the terms of this Policy and any applicable local policies. Failure to comply may result in disciplinary actions. Our suppliers are held accountable for complying with our policies and failure to do so may result in replacement or suspension of the commercial relationship.

Questions:

Questions about this Policy or reports of non-compliance may be directed to local management or the Procurement and Supply Chain Optimization department via procurement@silganspecialty.com. Silgan Specialty Packaging does not tolerate retaliation for making a good faith report of non-compliance under this Policy.