ANCHOR GLASS CONTAINER CORPORATION

SUPPLIER CODE OF CONDUCT

Anchor Glass Container Corporation (“Anchor”) is committed to socially responsible, professional, and ethical business practices and strives to align this commitment with Anchor’s purchasing policies. Anchor’s Supplier Code of Conduct (the “Supplier Code of Conduct”) applies to all suppliers, vendors, contractors, consultants, agents, and other providers of goods and services (each, a “Supplier”). This Supplier Code of Conduct summarizes Anchor’s expectations of its Suppliers and reflects Anchor’s concern for all individuals, including Suppliers’ workers. While local customs and laws vary by country, the importance of human rights is a worldwide and universal constant, and this Supplier Code of Conduct is intended to reflect that importance. Anchor expects every Supplier to comply with all applicable federal and local rules and regulations relating to production, workers, and the environment. In addition, Anchor requires its Suppliers to understand this Supplier Code of Conduct and take all necessary steps to act in accordance with the provisions herein. Supplier shall retain documentation needed to demonstrate compliance with this Supplier Code of Conduct and provide Anchor with access to: (i) such documentation at any time upon Anchor’s request; and (ii) Supplier’s facilities for auditing purposes, provided appropriate confidentiality measures are in-place to protect privacy concerns.

 

Legal & Business Integrity

A. Compliance with Laws: Supplier shall comply with all applicable laws and regulations relevant to its business, including the implementation, maintenance, and continuous review of compliance in all business processes. In instances where applicable law and this Supplier Code of Conduct address the same topic, Supplier shall meet the most stringent of the overlapping requirements.

B. Confidentiality: Where information is confidential, Supplier shall use its best efforts to ensure that confidentiality is afforded to such information and only disclosed to employees on a need-to-know basis.

C. Conflicts of Interest: Suppliers are expected to avoid personal activities and financial interests which could conflict with their responsibilities to Anchor. Suppliers shall not seek gain for themselves or others through misuse of their positions or company property. All actual and potential conflicts (including those arising from the activities or interests of close relatives) are required to be disclosed to Anchor. Supplier shall have policies and procedures in place that promote fairness in its business dealings.

D. Corruption: In addition to compliance with the Foreign Corrupt Practices Act (FCPA) and all other applicable anti-corruption laws, Supplier must have a zero-tolerance policy for corruption, bribery, kickbacks, extortion, and all other similar activities. Supplier and its officers, directors, and employees must adhere to the highest standards of ethical business conduct and must not engage in any form of nefarious activities, whether directly or indirectly through third parties.

E. Continuous Improvement and Monitoring: Supplier practices continuous improvement across all business functions. This includes, but is not limited to, management systems, leadership development, skills development, and root cause analysis. These practices are implemented to ensure a safe, healthy, and productive environment, available to all employees and representatives. Annual or biannual reviews and frequent communication will be implemented to enhance performance across Supplier’s network.

F. Maintain Accurate Books and Records: Supplier shall commit to full and accurate financial disclosure in compliance with applicable laws, rules, and regulations and to maintaining its books and records in accordance with generally accepted accounting principles.

 

Labor Conditions

A. Child Labor: Child labor is strictly prohibited, and Anchor does not tolerate any form of child labor in its supply chain. Supplier shall comply with the minimum employment age defined by applicable law or regulation. Further, Supplier shall not hire any individuals under the age of 15, the local legal minimum working age, or the compulsory schooling age, whichever is higher.

B. Slave Labor, Forced Labor, and Human Trafficking: Anchor implements the zero-tolerance policies adopted by the U.S. and other governments to combat slavery or the trafficking of persons for any purpose. Suppliers are expected to uphold the same principles. Anchor strictly prohibits trafficking-related activities. There will be no tolerance for forced labor. All work must be voluntary, and workers must be free to leave work at any time or terminate their employment. Supplier shall not use forced or involuntary labor of any kind, including but not limited to prison labor, slave labor, debt bondage, indentured labor or otherwise.

C. Working Hours in Compliance with Applicable Laws: Supplier’s employees shall work in compliance with all applicable laws pertaining to the number of hours and days worked. Employees will be provided with reasonable daily and weekly work schedules, and adequate allowances will be made for time off.

D. Fair Compensation: All compensation paid to employees is compliant with applicable wage laws. Compensation includes minimum wages, overtime hours, and legally mandated benefits. Supplier must pay workers at least the minimum wage required by the applicable local laws and provide all legally mandated benefits, including holidays and leaves and applicable premium rates for overtime. Supplier shall not make any deductions from worker wages as a disciplinary measure.

E. Diverse Workforce Free from Harassment and Abuse: Anchor is dedicated to assembling a supplier base that reflects its culture of inclusion. Accordingly, Supplier shall endeavor to create mutually beneficial relationships with diverse suppliers. Supplier shall be committed to creating a workplace free of harassment and shall not subject workers to any form of harsh or inhumane treatment, including sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse.

F. Reporting of Violations, Concerns, and Grievances: Supplier shall encourage its employees to report all accidents, incidents, near-misses, non-compliance, or anything posing a risk to health and safety to the appropriate parties. Supplier shall have a reporting mechanism in place that allows employees to submit concerns and violations anonymously, such as an ethics hotline. Further, if Supplier believes that an employee of Anchor has engaged in illegal or otherwise improper conduct, Supplier must immediately report the matter to Anchor.

G. Discrimination EEO/Affirmative Action: Supplier shall abide by all applicable requirements of 41 CFR Part 60. Accordingly, Supplier shall not discriminate on the grounds of race, gender, ethnicity, disability, nationality, religion, philosophical belief, political belief, age, sexual orientation, family status, trade union activity or any other status protected by applicable local laws or custom. All workers must be treated with respect and dignity, and any non-compliance with this policy will be treated seriously.

H. Employees’ Rights to Associate and Bargain Collectively: Anchor recognizes and respects the right of employees to bargain collectively. This right in a workplace includes the ability to come together and to choose a representative, based on a majority vote, who will then negotiate with their employer over terms and conditions of employment. Supplier shall respect the right of workers to join and organize associations of their own choosing without fear of reprisal.

 

Health & Safety

A. Occupational Safety: Supplier must provide a safe and healthy workplace and implement procedures to prevent accidents and injury in the course of performing work-related duties. Supplier must have evacuation procedures, worker training and drills, appropriate first aid supplies, personal protective equipment, fire detection and suppression equipment, as well as clearly marked exits.

B. Accident Reporting: All on-the-job accidents must be reported, regardless of severity. Timeliness of reporting is enforced in order to begin investigation and promote the likelihood of findings. Reporting accidents also allows for appropriate measures to be taken and for injured employees to return to work as safely as possible.

C. Hazardous Material Safety: Supplier shall provide a safe environment for employees and outside contractors who work with or around hazardous materials and surrounding areas which may be affected by the presence of such materials. Supplier must post material safety data sheets in the primary language of workers and train workers in the labeling, safe handling, use and storage of any hazardous materials.

 

Environmental Management

A. Respect for the Environment: Anchor is committed to environmental protection and stewardship. To that end, Supplier shall comply with all applicable environmental laws and regulations. Supplier will deliver goods and services to Anchor in a way that respects the protection of the natural environment. Insofar as possible, Supplier shall promote processes and technologies that identify and assess environmental risk and adopt and implement appropriate measures to minimize and eliminate such risk.

B. Energy and Resource Consumption, Pollution Prevention, and Waste Minimization: Supplier shall emphasize the importance of waste minimization, pollution prevention, energy consumption, and also look for opportunities to reuse resources. Appropriate energy management shall be performed to reduce the burden on people’s health and the environment. Resource conservation will be effectively integrated into Supplier’s business decision-making, including but not limited to identifying, monitoring, and measuring water, energy, wastewater, and emissions.

C. Adherence to Food Quality and Safety Standards: Anchor realizes the importance of food safety and sustainability. To promote such importance, Supplier shall comply with all guidelines and regulations regarding food safety and management.

D. Traceability: At any time upon Anchor’s request, Supplier shall disclose the origin of all materials used in the goods and/or services provided to Anchor. Supplier recognizes the necessity of traceability, including but not limited to the tracking of batch-lot data, purchase order (PO) data, and other operational information.