Statement of Business Principles
At Pregis, ethics, integrity and lawful conduct are everyone's responsibility. We strictly adhere to laws governing our business and associate practices. Our goal is to instill within our culture the highest ethical and professional standards. We know that integrity and excellence in these areas will lead us to success. At Pregis, no business requirement ever justifies an illegal, unethical, immoral, or unprofessional act. Pregis holds ethics, integrity, and lawful conduct among its topmost priorities. Ethical and lawful conduct is essential to protecting Pregis' worldwide businesses and reputation. Each employee, regardless of position or area of responsibility, is responsible for upholding our Business Principles in their daily activities and for seeking help when the proper course of action is unclear.
The Statement of Business Principles provides direction in areas where special care may be needed. The following policy examples outline specific standards of legal and ethical conduct that is expected from our employees and from the company as a whole. Adhering to these laws and standards is the key to our long-term success, our reputation for excellence as a company, our personal brand and to the world in which we live.
Pregis will not engage in practices that limit competition such as price fixing and division of markets. Nor will Pregis engage in practices to unlawfully restrict a competitor's opportunities.
Free competition is healthy for business and good for consumers. The antitrust laws of the United States and similar laws of other countries govern the day-to-day conduct of business in setting prices and other aspects of the purchasing and marketing of goods and services. These laws protect consumers from illegal competitive actions such as price fixing and division of markets. It is vital to follow the laws of the United States and other countries that prohibit practices undermining competition.
Pregis will compete solely on the merits of its products and services. Pregis will succeed by satisfying its customers' needs, not by unlawfully limiting a competitor's opportunities.
Pregis, acting independently, is free to price our products and services as we choose. We prohibit maintaining or expanding our market share through illegal or restrictive practices.
Foreign Corrupt Practices Act
Pregis, all its employees worldwide, agents, distributors, and other representatives must comply with the Foreign Corrupt Practices Act.
This Act prohibits payments or offers of payments of anything of value to foreign officials, foreign political parties, or candidates for foreign political office in order to obtain, keep, or direct business. Indirect payments of this nature made through an intermediary, such as a distributor or sales representative, also are illegal.
This Act also requires that Pregis maintain a system of internal accounting controls and keep accurate records of transactions and assets.
The following activities are prohibited:
• maintaining secret or unrecorded funds or assets;
• falsifying records;
• providing misleading or incomplete financial information to an auditor
Foreign Economic Boycotts
U.S. laws prohibit participating in or cooperating with illegal economic boycotts supported by foreign nations, such as the Arab boycott of Israel. Pregis, all its employees worldwide, and its joint venture partners, agents, distributors, and other representatives will strictly comply with U.S. "anti- boycott" laws and policies. The Arab League boycott of Israel is the principal foreign economic boycott that U.S. companies must be concerned with today. The antiboycott laws, however, apply to all boycotts imposed by foreign countries that are unsanctioned by the United States.
There are many other prohibited activities. Employees must be alert to the possibility that boycott related provisions can appear in the "standard" language in documents such as contracts, letters of credit, and shipping documents. Because this is a complex legal area, if employees identify or receive any boycott- related language or request, they are required to report it to management or the Corporate Controller’s Office. The law also requires that requests to take boycott-related actions (including requests to provide information or to agree to boycott-related terms) be reported to the U.S. Government.
At present, the following countries are sanctioned by the United States: Crimea region of Ukraine, Cuba, Iran, North Korea, and Syria.
The U.S. Internal Revenue Service (IRS) has identified the countries cooperating with an international boycott that raises issues related to claiming foreign tax. These countries are: Iraq, Kuwait, Lebanon, Libya, Qatar, Saudi Arabia, Syria, United Arab Emirates, and Yemen. This list is subject to change.
Exports & International Trade Restriction
Pregis' worldwide operations require an awareness of international trade laws. Pregis, all its employees worldwide, its agents, distributors, and other representatives will comply with these laws, including U.S. trade sanctions, economic embargoes, and export and re-export controls.
The export of goods and technology (including transfers with no sale) from the United States is regulated by a number of very complicated laws and regulations. There are many factors in determining whether a product or technology can be exported, including the nature of the item, the country of destination, and the end-user or end-use. Export restrictions apply not only to the export of goods and services, but also to the licensing of software and the transfer of technology in many forms, such as plans, designs, training, consulting, and technical assistance. These restrictions can also apply to foreign-made products based on U.S. technology or that contain U.S. parts or components. Exporting goods or technology without the appropriate government approvals can result in the loss of export privileges and can subject a company to both civil and criminal penalties.
Financial Controls & Records
A variety of laws require Pregis to record, preserve, and report financial information to investors and government agencies. This information must present fairly Pregis' financial position and the results of Pregis' operations. Pregis employees involved in preparing, processing and recording such information will be held responsible for its timeliness, completeness and accuracy.
Employees must record financial information accurately, completely, and timely in accordance with U.S. generally accepted accounting principles. Financial information must be kept confidential and released only with proper authorization.
Biometric Information Privacy Act
Pregis and its third party electronic timekeeping vendors use employee biometric identifiers and information (collectively, “Biometric Information”) and related biometric technology in order to identify employees on Pregis’ electronic timekeeping systems. The Biometric Information is retained for the duration of the employee’s employment and is permanently destroyed within ninety (90) days after the termination of the employee’s employment, unless a longer retention period is required by subpoena, warrant, court order or other legal requirement.
Pregis' worldwide operations must comply with all applicable laws and regulations as well as the Statement of Business Principles and the policies and procedures that support them. To assist employees with the above, Pregis has established a toll-free Hotline: 844-972-0583
Employees, worldwide, may communicate confidentially, questions concerning this Statement of Business Principles, or suspected violations thereof, by calling the toll-free, 24-hour Hotline.
All reports of suspected violations will be investigated promptly and fairly on a confidential basis. No employee will be subject to reprisal for reporting in good faith a suspected violation, and all appropriate steps will be taken to keep confidential the identity of the reporting employee.