Ethics and Compliance

Significance

Importance To Berry Global and our Stakeholders

Ethical business practices form the foundation of our corporate responsibility. By operating with integrity, we not only mitigate operational risks but create a work environment that attracts and retains exceptional talent—ultimately protecting our reputation and ensuring long-term business viability.

Our commitment extends beyond mere compliance; we embrace environmental and ethical standards as catalysts for sustainable development and social progress. This proactive approach eliminates compliance risks while shielding us from financial penalties, legal consequences, and reputational damage.

Our Customer Relationships: Today's customers increasingly select partners based on demonstrated integrity and environmental stewardship. Our comprehensive ethics and compliance program drives sustainability throughout our operations, aligning with these evolving expectations and strengthening customer loyalty.

Investor Confidence: We recognize our fiduciary responsibility to maintain the highest ethical standards and environmental compliance, protecting shareholder value through principled business practices that support sustainable growth.

Our Approach

Berry’s Global Ethics & Compliance Program empowers us to operate with integrity by building a culture where ethical behavior is celebrated and expected. We equip our teams with clear guidance and practical tools for ethical decision-making and foster a workplace where everyone feels safe, respected, and valued. We are also committed to exceeding legal and regulatory requirements across all regions. Through these efforts, we protect our employees, business relationships, assets, and reputation while building enduring trust with our stakeholders. Berry’s commitment to ethical business practices is embedded throughout our organization. The VP of Labor & Compliance provides quarterly assessments of our program’s effectiveness and emerging compliance risks. To strengthen our ethical culture, we regularly conduct facility-wide ethics audits and deliver annual training on our Global Code of Business Ethics. We enable ethical decision-making at every level through comprehensive training and open communication. In addition, we maintain a strong speak-up culture, encouraging team members to voice concerns through our confidential ethics helpline, backed by our firm commitment to protect them from any form of retaliation. Our customers value businesses that demonstrate integrity and environmental responsibility, and our investors expect us to uphold the highest ethical standards and comply with environmental regulations so as not to damage the value of our business.. Learn more about our ethics and compliance policies.

Values and Behaviors: The Foundation of Our Culture

We are committed to creating a work environment that is safe, ethical, inclusive, and rewarding for every employee and partner. Our four core values—Partnerships, Excellence, Growth, and Safety—bring our ethics and compliance commitments to life, shaping our policies, guiding our decisions, protecting our reputation, and strengthening our ethical culture.

Core Values

Safety: Our Highest Priority
We place safety above all else, pursuing it relentlessly throughout our operations. Our rigorous standards ensure facilities remain safe and environmentally responsible, reflecting our fundamental commitment to protecting people and planet.

Partnerships: Building Connections That Matter
We cultivate strong, sustainable relationships across our entire ecosystem. By treating employees, customers, suppliers, and communities as valued partners, we create collaborative foundations for mutual success.

Excellence: Raising the Standard
We pursue excellence through continuous improvement—optimizing processes, enhancing sustainability initiatives, and delivering superior products and services. By investing in employee development, we empower our teams to exceed customer expectations.

Growth: Expanding Possibilities
We embrace multidimensional growth as essential to our success—financial performance, customer relationships, employee development, product innovation, and global market expansion all contribute to our forward momentum.

Guiding Behaviors

Our values find expression through four key behaviors that define how we operate as a company, as employees, and as community partners:

United: One Team, Many Strengths
We function as One Berry, leveraging our collective power while valuing the unique talents, perspectives, and diverse backgrounds each individual brings to our organization.

Focused: Clear Vision, Shared Purpose
We maintain unwavering focus on creating lasting value for all stakeholders—our company, customers, employees, shareholders, and communities—ensuring decisions align with long-term success.

Agile: Responsive and Deliberate
We move quickly and purposefully, encouraging action-oriented problem-solving that delivers exceptional service. This intentional agility drives continuous advancement in our performance, products, services, and culture.

Accountable: Integrity in Action
We understand that success depends on honoring our commitments. We conduct business with uncompromising integrity, adhering to the highest ethical, moral, and legal standards in everything we do.

Highlights and Target Progress

Key Metrics

The below metrics are based on Berry's fiscal years unless otherwise noted. 

Key Strategies

Business Ethics 

Workplace Respect and Inclusion

We've strengthened our commitment to non-discrimination and anti-harassment by establishing a comprehensive, publicly available policy that complements our Employee Handbook and Global Code of Business Ethics. This standalone policy addresses both sexual and non-sexual harassment while reinforcing our Speak Up culture that protects individuals from retaliation. We reinforce these principles through mandatory annual training for all team members, with enhanced guidance for management to ensure consistent application across our organization.

Competitive Integrity

We've substantially enhanced our approach to preventing anti-competitive behavior through robust internal controls, targeted training, and strategic communication. Our recently revised Global Competition Policy and updated Fair Competition section in our Global Code of Business Ethics emphasize our core values of honesty, integrity, and transparency. These resources help employees identify potential warning signs and provide clear guidance for handling situations where competitors attempt to discuss sensitive information.

To ensure widespread understanding, we deliver specialized anti-competitive behavior training in multiple languages to all office-based team members. While we maintain a strong record with no confirmed cases of anti-competitive behavior, we actively promote our Speak Up program, which encourages reporting without fear of retaliation.

Oversight and Tone at the Top 

The Ethics & Compliance Program is led by the Director of Ethics & Compliance who reports to the Chief Legal Officer and provides quarterly reports to the Audit Committee. The Audit Committee plays a critical role in overseeing the Ethics & Compliance Program, which includes being updated on compliance risks and the effectiveness of our program to mitigate those risks. We also have an Ethics Committee, which is a cross-functional team of leaders across the organization and around the globe that provides operational guidance to the program.

“By joining as One Berry, we have earned recognition as a global leader in our industry. As such, we all share in the responsibility to not only maintain this leading position, but in further strengthening it. In so doing, we will never compromise our Values, Brand, or Reputation to win business." – Kevin J Kwilinski, CEO. 

Global Code of Business Ethics 

Our Global Code of Business Ethics is the foundation for our Ethics & Compliance Program. It applies to all team members around the globe, including our officers and directors. We have a clear expectation that all team members familiarize themselves with the Code. Our leaders carry additional responsibilities to not only understand the Code, but show how we put our Values into practice and recognize those who exhibit them.

Our Code provides guidance to team members who confront situations where the right course of action is unclear. Its practicality is shown through red flags, checklists, and a decision-making framework. Most importantly, it offers a host of resources to seek guidance and Speak Up.

Beginning with our 2024 fiscal year, the Company’s Internal Audit program began including a process designed to drive improved understanding of, and compliance with, our Code. Sites will be selected for audit based on a weighting of quantitative and qualitative factors, with 100% of sites audited within a 4-year period.

Anti-Corruption 

Berry’s commitment to preventing bribery and corruption is unwavering. We train our team members to understand that while bribery and corruption laws vary between countries, our commitment to doing business the right way, one consistent with our values, goes beyond any specific law or regulation. We follow all local laws and regulations, but some situations may require an even higher expectation from our team members. 

Ethics Training and Communication 

We are committed to providing a safe, ethical, inclusive, and rewarding work environment for every team member and partner. Through our ethics training and communication program, we strive to equip team members across all levels of our organization with the necessary resources and skills to make decisions of the highest ethical standards, conduct business according to legal regulations, and Speak Up without fear of retaliation. Team members are expected to complete their annual Code of Conduct training, along with any specific training that is applicable to their responsibilities. We send out regular Ethics Tips and provide FAQs to help with their decision-making. In all trainings and communications, we encourage anyone with a question to Speak Up and seek guidance.

This is accomplished through multi-media training, including Skillsoft’s suite of ethics, an eLearning program that engages team members in ethical decision-making processes across a variety of topics. Over the last two years, these have included human rights, fair competition, diversity, anti-discrimination, insider trading, global anti-bribery and anti-corruption, respect in the workplace (anti-harassment), cybersecurity, red flags, misconduct, and more.

Expanded Learning Opportunities 

We also offer a variety of instructor-led ethics courses, including Anti-Bribery/Anti-Corruption, Ethical Leadership, and Ethical Business Practices. These sessions allow participants to ask real-time questions and receive feedback.

We will continue leveraging our train-the-trainer model to educate our workforce on the annual Global Code of Business Ethics. This program helps set a strong tone at the top by allowing trainees to hear key Ethics & Communication messages from their local leader. The eLearning program will also be expanding to include courses on Human Rights, Gifts & Entertainment, Conflicts of Interest, and Protecting Confidential Information.  

Speaking Up 

All Berry employees are expected to Speak Up when they have reason to believe someone violated, or may violate, our Global Code of Business Ethics. We do not expect the reporter to have all the information, but all concerns should be made in "good faith." There are many options to report concerns or seek guidance, including your Manager, Human Resources, Ethics & Compliance, and the Ethics Helpline. 

Commitment to Non-Retaliation 

Berry believes in creating a safe and positive work environment. All forms of retaliation against those who report a concern in good faith have no place here. We have zero-tolerance for those who retaliate against others as it harms the reporter and our culture of integrity. Leaders have an additional responsibility to create an open and inviting environment to raise concerns.

If you believe that you have been retaliated against, we encourage you to report your concern immediately. For more information, view our Non-Retaliation Policy. 

Ethics Helpline 

Berry has an independent, third-party provider to manage our global Ethics Helpline 24/7/365. You can either call using your country code, making a web submission, or using the QR Code. It can be used by team members, suppliers, or any stakeholder. Your concern will be kept confidential to the greatest extent possible. All investigations are conducted thoroughly and efficiently. You also have the option to remain anonymous. If you would like to share more information at any point throughout the investigation or ask for a status update, the Helpline provides a feature for you to follow-up. Berry may also use that mechanism to contact the reporter with questions during the investigation.

At the foundation of business ethics is the safety of holding each other accountable for responsible actions. The continuation our Ethics Helpline, revamped in 2021, continues to grow in utility by team members at all levels of our global organization. The ethics helpline is easily accessible from team members’ mobile devices through QR codes placed on posters across our facilities to encourage team members to speak up.

As part of this commitment, we continue to grow engagement with the Ethics Helpline by reinforcing our Speak Up culture where employees feel safe when raising a concern. This includes regular communications from company leaders that encourage reporting and reinforce our belief that speaking up brings value to our organization. In addition, our Non-Retaliation Policy will help ensure concerns reported through the helpline are escalated quickly, remain confidential, and are free from retaliation. This will provide greater visibility and confidence to our employees by offering reassurance that those who speak up can identify and trust they will be taken seriously without fear of reprisal.

While the number of helpline reports have increased, we continue to address reporting hesitancy through a streamlined process that addresses and closes reports in an average of 24 days. This is consistent with the average completion time recorded in Navex Global’s 2023 Hotline & Incident Management Benchmark Report.

Environmental Compliance 

Our environmental management practices protect both the planet and our business. We closely monitor our environmental impact through detailed tracking and reporting, while staying current with regulations to ensure full compliance. Our Impact 2025 strategy sets clear benchmarks for environmental performance, supported by annual audits and our company-wide Environmental Management System and Policy. This comprehensive approach advances sustainability and social responsibility while protecting us from compliance issues, fines, legal challenges, and reputation damage. Berry operates in accordance with the country legal environmental laws and regulations. If required, air quality emissions requirements are tracked, monitored, and reported.

Environmental Sanctions 

To ensure the success of our environmental management program, we operate an Environmental Management System (EMS) across our business, conduct annual environmental audits, and clearly communicate our environmental commitments through our company-wide Environmental Management policy. 

Environmental Management Systems 

We consistently address non-compliance risks and improve environmental and business performance through our company-wide EMS. Focused on systematic identification, management, and improvement of the high-risk areas of our business, our EMS helps strengthen our policy, establish appropriate objectives and targets, and introduce and examine ways to achieve policy commitments.

To enhance accountability and progress tracking against performance targets and public commitments, we encourage our facilities to develop site-specific EMSs. The International Organization for Standardization (ISO) is an independent, nongovernmental organization that develops standards to ensure the quality, safety, and efficiency of products, services, and environmental management systems. In 2024, 58 (25% of total facilities) held the ISO 14001:2015 environmental management certification, and ISO 50001:2018 energy management certifications were held by 37 facilities (16%).

Environmental Auditing 

Environmental compliance audits allow us to identify areas for improvement, provide guidance for achieving better compliance, and advise on potential forthcoming changes in legislation. We developed and implemented a risk-based ranking method that requires facilities to receive environmental audits each fiscal year. During the EHS planning phase for the new fiscal year, a proposed list of facilities is developed with audit plans that help ensure minimal disruption to the operational process. Across 2024, internal and external environmental audits were completed across 45 of our facilities.

Disclosures 

Contribution to the Sustainable Development Goals (SDGs)

SDG 8: Decent Work and Economic Growth

By upholding business ethics, including treating our employees fairly and supporting their well-being, we foster sustainable economic growth and create opportunities for stable employment. 

SDG 12: Responsible Consumption and Production

Responsible consumption and production can only be achieved through compliance with ethical business practices and environmental regulations. We integrate ethics and compliance into all aspects of our business to help ensure our operations are guided by the principles of sustainability. 

SDG 14: Life Below Water

Environmental compliance plays a crucial role in reducing pollution by ensuring environmental regulations are met. Through compliance, we mitigate our environmental impact and protect marine ecosystems.

SDG 16: Peace, Justice, and Strong Institutions

We believe in conducting business in accordance with the highest ethical, moral, and legal standards, with due care, and in the best interest of our company, our employees, and our shareholders. This in turn fosters the growth of peaceful and inclusive societies with accountable and transparent institutions. 

 

GRI and SASB Alignment 

GRI 2-23 Policy Commitments
GRI 2-24 Embedding Policy Commitments
GRI 2-25 Processes to Remediate Negative Impacts
GRI 2-26 Mechanisms for Seeking Advice and Raising Concerns
GRI 2-27 Compliance Laws and Regulations
GRI 205(3-3) Anti-Corruption
GRI 205-1 Operations Assessed for Risks Relating to Corruption
GRI 205-2 Communication and Training About Anti-Corruption Policies and Procedures
GRI 205-3 Confirmed Incidents of Corruption and Actions Taken
GRI 206(3-3) Anti-Competitive Behavior
GRI 303-2 Management of Water Discharge-Related Impacts
GRI 307(3-3) Environmental Compliance
GRI 307-1 Non-Compliance Environmental Laws and Regulations
GRI 404(3-3) Training and Education
GRI 404-2 Programs for Upgrading Employee Skills and Transition Assistance Programs
GRI 406(3-3) Non-Discrimination
GRI 406-1 Incidents of Discrimination and Corrective Actions Taken
GRI 419(3-3) Socioeconomic Compliance
GRI 419-1 Non-Compliance Laws and Regulations in the Social and Economic Area
SASB RT-CP-140a.3 Number of Incidents of Non-Compliance Associated with Water Quality Permits, Standards, and Regulations

Last updated: March 17, 2025