OBJECT: CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT DISCLOSURE

DATE: 04/29/2015

Coveris Flexibles US LLC
8600 West Bryn Mawr Avenue, Suite 800N, Chicago, IL 60631

The California Transparency in Supply Chain Act took effect on January 1, 2012. The Act seeks the elimination of slavery and human trafficking from product supply chains and requires that companies disclose their efforts to ensure that their supply chains are free from slavery and human trafficking. Coveris supports the goal of eradicating slavery and human trafficking in all forms.

As a responsible corporate citizen, Coveris is dedicated to conducting business in a lawful and ethical manner, and we expect our suppliers to conduct themselves in such a manner. Coveris complies with the laws regarding slavery and human trafficking in the countries in which we are doing business. Additionally, our employment practices reflect principles supportive of a work environment that provides equal opportunity, respects the dignity and worth of every worker, encourages employee initiative, and challenges individual capabilities. We value a diverse work force and endeavor to identify, hire and promote employees with a wide range of skills and attributes. We strictly prohibit workplace harassment and discrimination, and we take all necessary steps to ensure the occupational health and safety of our employees and the safety of the communities in which we operate.

The following is Coveris’ disclosure pursuant to the Act.

  1. Verification of product supply chains for human trafficking and slavery. Almost all of the materials incorporated into our products produced in California are sourced in the United States and Canada. Although human trafficking and slavery exist in the United States and Canada, these countries are not at a significant risk for these activities, based on the Department of Labor’s List of Goods Produced by Child Labor or Forced Labor (2014), and are considered Tier 1 countries (with the highest level of compliance in prohibiting severe forms of trafficking) based on the U.S. Department of State Trafficking in Persons Report (2014). Because of the low risk, we have not employed a third party for verification.
  2. Audits of suppliers. Almost all of our direct suppliers for our California plants are located in the United States and Canada. Because of the low risk of slavery and human trafficking in the company’s supply chain, we do not currently audit our suppliers for compliance.
  3. Direct supplier certificates of compliance. Our terms require that our direct suppliers comply with all applicable federal, state, and local laws, and rules and regulations of any governmental authority, this includes any applicable laws pertaining to slavery and human trafficking.
  4. Internal accountability. As a condition of employment, we require our salaried employees to acknowledge and agree to comply with our corporate Code of Conduct.  If any of our salaried employees engage in conduct which violates the Code, the salaried employee will be dealt with appropriately, including possible termination of employment.  Regarding materials suppliers, the Coveris Ethics of Business, Global Standards for Suppliers, document is provided with RFQs.  This document defines minimum business ethics requirements of materials suppliers, including directly addressing the prohibited use of forced labor.  Failure of materials suppliers to observe the standards outlined in this document will result in Coveris ceasing to do business with such materials suppliers.
  5. Training. We currently do not provide training on issues involved in slavery and human trafficking.