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Title Human Resources Business Partner
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CODE OF ETHICS POLICYPolicy Type: General Business Policy Date: Street Address .15.2019 Policy Number: 001Page - 1 - of Street Address  This document is uncontrolled if printed Table of Contents:1 Introduction 2 2 Harassment and discrimination 3 3 Health and safety 4 4 Conflict of interest 5 5 Outside employment and activities 6 6 Dissemination of corporate information 7 7 Protection of GPC property and information 8 8 Electronic communication 9 9 Antitrust Street Address  10 Anti-bribery 12 11 Entertainment and gift policy 13 12 Foreign economic boycotts 14 13 Exports and international trade restrictions 15 14 Financial controls and records 16 15 Political contributions and activities 18 16 Environmental stewardship 19 17 Reporting violations 20 CODE OF ETHICS POLICYPolicy Type: General Business Policy Date: Street Address .15.2019 Policy Number: 001 Page - 2 - of 21 This document is uncontrolled if printed 1. Introduction.Graham Packaging (GPC or the Company), holds ethics, integrity, and lawful conduct among its topmost priorities. No business requirement ever justifies an illegal, unethical, immoral, or unprofessional act. Our success in business depends upon maintaining the trust of employees, customers, other commercial partners, government authorities and the public. This Statement of Business Principles and Code of Ethics Policy (the Code) is an expression of the professionalism we strive for throughout our business, and of the professionalism, we expect of our associates. The principles contained within the Code are based on ethical and legal behavior fair, courteous and respectful treatment of fellow employees and others with whom we interact fair and appropriate consideration of the interests of other stakeholders (customers, other commercial partners, government authorities and the public) and of the environment professionalism and good business practiceThis Code presents the basic expectations and general principles guiding how GPC does business. Each employee, regardless of position or area of responsibility, is responsible for upholding the Code in his or her daily activities and for seeking help when the proper course of action is unclear. Any violation of the Code is considered misconduct and will be addressed appropriately and timely. If anyone is in doubt about the appropriate course of conduct in their business activities, or questions how GPCs standards and principles apply to a specific situation, they should ask. A simple, early question often clarifies and avoids potentially troubling situations. The Code does not attempt to address every situation or answer every question. The principles underlying the Code are often directional and in many situations require an exercise of judgment. If anyone has questions about the Code, concerns about someones workplace conduct or question whether a proposed course of action is consistent with the Code, you should seek guidance from your direct supervisor. However, if your feel that would be inappropriate, you may contact the Chief General Counsel, your Human Resources Business Partner or Internal Audit. There will be no retaliation or penalty for honest and good faith reporting, even if it turns out reported concerns were unfounded. If you do not feel comfortable talking with your supervisor, you may contact your location Human Resources Business Partner, or call the toll-free Compliance Hotline for your location, which can be identified via the GPC Compliance Hotline Policy. All appropriate steps will be taken to keep calls and letters confidential. Calls may be made anonymously where permitted by law. The identity of a person contacting the Chief General Counsel or toll-free Compliance Hotline will not be given to anyone except as required by law or as needed for investigative purposes. Actions contrary to this policy are, by definition, harmful to GPC and its reputation. Violations, even in the first instance, may result in disciplinary action up to and including dismissal. This policy is not an employment contract, and compliance with it does not create a contract for continued employment. GPC and its employees are subject to the laws of many countries and other jurisdictions around the world. Employees are expected to comply with the Code and with all applicable laws, rules and regulations. If a provision of the Code conflicts with applicable laws, the rules and regulations of the laws control and should be followed. CODE OF ETHICS POLICYPolicy Type: General Business Policy Date: 01.15.2019 Policy Number: 001 Page - 3 - of 21 This document is uncontrolled if printed 2. Harassment and discrimination.PolicyWe will not unlawfully discriminate based on race, color, gender, age, religion, national origin, disability, veteran status, marital or family status, sexual orientation, gender identity, or any other category protected by relevant law. All employment decisions, including hiring, performance appraisals, promotions and discharges will be made without unlawful consideration of any such criteria. It is improper for any employee to harass another employee by creating an intimidating, hostile or offensive work environment through verbal abuse or name-calling, threats, intimidation or similar improper conduct. Employees may not act violently or threaten violence while at work, and may not bring or use a weapon on a work site.CommentsThis policy applies worldwide to all employees. In some locations, local statutory requirements may require employers to conform to additional locally mandated norms.Threatening, intimidating or violent behavior will not be tolerated. Harassment can take on many forms, all of them unacceptable as shown in the following examples jokes, insults, threats, and other unwelcome actions about a persons characteristics as described above unwelcome sexual advances, flirtations, sexually suggestive comments or conduct, requests for sexual favors, and other unwelcome verbal or physical conduct of a sexual nature the display of sexually suggestive objects or pictures comments or conduct suggesting that an employees cooperation with, or refusal of sexual or other harassing conduct will have any effect on the employees employment, assignment, compensation, advancement, career development, or any other term or condition of employment verbal or physical conduct that negatively impacts anothers work performance or creates a fearful or hostile work environment (e.g., bullying)We will not tolerate this type of behavior from employees or from others at our worksites, and encourage all employees to join us in keeping a harassment free workplace.Your ResponsibilitiesDo not make or tolerate sexual jokes,comments about a persons body, graphicstatements about sexual matters, orengage in offensive behavior of a sexualnature.Do not make or tolerate jokes,comments, remarks or treat anyemployee differently because of his or herrace, color, sex, national origin, age,religion, disability, marital or family status,veteran status, or any other non-businessrelated consideration. Doing so isdiscriminatory.Do not display sexually suggestiveobjects or pictures at work.Do not ask or make comments about co-workers sexual conduct or sexualpreference.Never suggest or imply that anemployees job will be affected by his orher response to a sexual advance.Create an atmosphere free of anysuggestion of discrimination orharassment.For further information onHarassment and Discrimination,consult the location HumanResources Business Partner.CODE OF ETHICS POLICYPolicy Type: General Business Policy Date: 01.15.2019 Policy Number: 001 Page - 4 - of 21 This document is uncontrolled if printed 3. Health and safety.PolicyWe will not compromise health or safety in the workplace for profit or production. Safety rules and procedures are mandated in all of our plants, offices, and work sites. Each of us must perform his or her job following these health and safety rules, and must promptly report any concerns, safety violations or incidents to his or her supervisor or the Human Resources Business Partner. Employees must not use, possess, manufacture, or transfer illegal drugs on company property. Employees are not allowed to work if under the influence of alcohol or illegal drugs. Doing so can result in termination of employment. Additionally, misusing legal drugs in the workplace is not allowed. We will not let someone work if we believe that such persons use of legal drugs could create an unsafe condition.CommentsWe are firmly committed to having all employees work in a safe and healthy work environment.Employees must know, understand, and comply with all safety rules and regulations. They must know that no task is more important than their personal safety and that of their fellow employees. Following these requirements, helps ensure not only our safety, but also the safety of others. Your ResponsibilitiesAlways comply with your facilitys healthand safety rules and procedures, and besure of the safe way to perform a task.If unsure, ASK!Always take appropriate safetyprecautions, including wearing and usingprotective safety equipment includingseat belts while driving or riding incompany vehicles.Never compromise your personal safetyprocedures.Report to your supervisor or the facilityHealth and Safety Coordinator for yourlocation any hazardous conditions,improper use of safety equipment, or anyfailure to follow safety procedures; or youmay report suspected violations bycalling the Companys toll-freeCompliance Hotline for your location.Also report any job-related near miss,injury or illness to your supervisor as soonas possible.Do not bring illegal drugs or alcohol ontoGPC property, or perform GPC businessor be on GPC premises while under theinfluence of any illegal drug(s) or alcohol.Never use prohibited or controlledsubstances or alcohol while in vehiclesowned, leased or used for GPC business.If you are taking a medication that youbelieve might affect your ability to safelydo your job, advise your supervisor.For further information onWorkplace Standards orProhibited Substances, consultwith the location HumanResources Business Partner.CODE OF ETHICS POLICYPolicy Type: General Business Policy Date: 01.15.2019 Policy Number: 001 Page - 5 - of 21 This document is uncontrolled if printed 4. Conflict of interest.PolicyAll employees are prohibited from taking any actions that would create a conflict of interest with GPC and should avoid even the appearance of a conflict of interest. GPC resources are to be used only for approved purposes. CommentsA conflict of interest is a situation in which an employees personal interest or benefit interferes with his or her responsibilities as an employee. Employees must not accept payments, gifts, entertainment, or other favors that go beyond the common courtesy usually associated with good business practice or that might be regarded as placing himself or herself under some obligation to a supplier or customer. Some locations may adopt local rules setting more specific limits on the acceptance of gifts, meals, or entertainment, such as particular monetary thresholds. Should your location have such local rules, they will be communicated to you and shall be in addition to the general principles outlined in this Code.Unless approved in advance, no employee may hold a position with, or have a substantial financial interest in, any business that conflicts with or might appear to conflict with that employees work on behalf of GPC. Should any of the above situations occur, communication between employees and their supervisor is of utmost importance, and the parties concerned shall attempt to resolve the matter in good faith.Your ResponsibilitiesPlace compliance with laws and ethicalprinciples above private gain.Do not solicit or accept anything of morethan minor value from business suppliers.Do not have a position with, nor financialinterest in, another business thatinterferes or appears to interfere with ourduties or responsibilities, unless approvedin advance by the Chief General Counsel,or the location Human ResourcesBusiness Partner.Do not conduct/transact Companybusiness with a relative unless approvedin advance by the Chief General Counsel,or the location Human ResourcesBusiness Partner.Disclose any financial interest in orposition with any competitor.Report suspected violations of conflict ofinterest procedures to the Chief GeneralCounsel, or the location HumanResources Business Partner, or reportsuspected violations by calling the toll-free Compliance Hotline for your location.For further information on Conflictof Interest, consult with thelocation Human ResourcesBusiness Partner, or the ChiefGeneral Counsel.CODE OF ETHICS POLICYPolicy Type: General Business Policy Date: 01.15.2019 Policy Number: 001 Page - 6 - of 21 This document is uncontrolled if printed 5. Outside employment and activities.PolicyA full time employee's primary work obligation is to GPC. Outside activities, such as a second job or self-employment, must be kept totally separate from GPC employment and not interfere with GPC job responsibilities or performance.CommentsWe respect the privacy of every employee in the conduct of his or her personal affairs. No employee may run a personal business on GPC time or using GPC resources. Similarly, no employee can allow such outside activities to detract from his or her job performance or require such long hours that the outside activity adversely affects the employees physical or mental effectiveness. Generally, no employee can perform services for, nor serve as an employee, consultant, officer, or director of any competitor, customer, or supplier of GPC. Your ResponsibilitiesDo not use GPC time or resources forpersonal or outside business matters.Do not work on behalf of competitors,suppliers, or customers of GPC withoutprior authorization by the Chief GeneralCounsel or the location Human Resourcesrepresentative.Inform your supervisor, or the locationHuman Resources representative of anyoutside business position (other thancharitable, educational, or religious) thatmight be viewed as conflicting with yourGPC duties or responsibilities.For further information on OutsideEmployment and Activities, consultwith the location Human ResourcesBusiness Partner.CODE OF ETHICS POLICYPolicy Type: General Business Policy Date: 01.15.2019 Policy Number: 001 Page - 7 - of 21 This document is uncontrolled if printed 6. Dissemination of corporate information.PolicyEmployees must not respond to requests for financial or business information about GPC from outside sources such as the government, media, press, financial community, or the public, unless authorized to do so. Such inquiries are to be referred to the Chief General Counsel.CommentsWe will maintain a coordinated and consistent posture in relations with the various segments of the newsgathering industry. All contact with news media concerning the affairs of GPC, financial or otherwise, including written and oral communications and the release of photographs, must be coordinated through the Chief General Counsel, who will coordinate with the appropriate parties. Confidential GPC information should be released only to employees, agents or representatives on a need-to-know basis.Your ResponsibilitiesRefer requests for information of any type tothe Chief General Counsel for handling andreply.Refer inquiries regarding current or formeremployees, other than by the news media,to the location Human Resources BusinessPartner. News media inquiries should bereferred to the Chief General Counsel.For further information on theDissemination of CorporateInformation, consult with the ChiefGeneral Counsel.CODE OF ETHICS POLICYPolicy Type: General Business Policy Date: 01.15.2019 Policy Number: 001 Page - 8 - of 21 This document is uncontrolled if printed 7. Protection of GPC property and information.PolicyEmployees are responsible for protecting GPC-owned or GPC-leased property and equipment. This responsibility extends to not only tangible assets such as money, physical materials, inventory, equipment, and real property, but also to intangible property, such as business plans, trade secrets, computer programs, technologies, and other confidential or proprietary information of GPC or of others, including our customers and suppliers. We treat company assets with the same care we would if they were our own.CommentsGenerally, GPC property must not be used for any purpose other than for GPC business. Employees must not borrow, give away, loan, sell, or otherwise dispose of GPC property regardless of conditions without specific authorization. Reasonable precautions must be taken against theft, damage, or misuse of GPC property.GPC property includes information developed by employees and may include information received from outside GPC. It may consist of financial, commercial or technical data, or may relate to payroll, salaries, benefits or personnel records. It may include information about employees, customers, potential customers, or information owned by others entrusted to the GPC. Employees who receive or learn of confidential business information or trade secrets of GPC or others, may not, for non-GPC purposes, disclose that information to third parties (including friends and family members) or make any other non-GPC use of such information.All employees are responsible for protecting the companys confidential information. Any dissemination of information outside of the business should be approved by the appropriate manager(s). If there is a question regarding the sharing of information, please contact your Human Resources Business Partner or the Chief General Counsel.We do not destroy official company documents or records before the retention time expires, but unless otherwise directed with respect to specific items do destroy documents when they no longer have useful business purpose. Employees should contact their supervisor if they are unclear whether a document may or may not be destroyed.Your ResponsibilitiesExercise appropriate care, custody andcontrol over GPC property (includingsupplies, equipment, facilities, files,documents, films, and electronicallyrecorded data or images). Additionally,exercise appropriate care, custody andcontrol over GPC intangible properties(including business plans, trade secrets,compliance programs, technologies, andother confidential or proprietaryinformation).Do not use GPC equipment, includingcomputers, for excessive personal useand/or to browse inappropriate web sites.Do not duplicate proprietary ortrademarked software for personal use.Keep confidential information storedproperly when it is not being used.For further information on GPCProperty, consult with thelocation Controller.CODE OF ETHICS POLICYPolicy Type: General Business Policy Date: 01.15.2019 Policy Number: 001 Page - 9 - of 21 This document is uncontrolled if printed 8. Electronic communication (Use of computers,internet, and email).PolicyWe will protect GPC computing systems and computerized information from unauthorized access, use, modification, copy, disclosure, or destruction. Use may be reviewed for consistency with legal requirements. Employees and others who violate this policy may be subject to disciplinary action. Security incidents should be immediately reported by employees to their direct supervisors. If this is not feasible to report to the supervisor, employees should call the toll-free Compliance Hotline for their location. Use of company computer systems in manners that do not support company values or business purposes is prohibited.CommentsAuthorized users will be issued company-approved accounts. Unauthorized access to company computerized information, any use of computer systems or information that constitutes illegal activity and sharing computer user accounts or other accounts assigned for individual use is prohibited. Personal Use of Technology ResourcesOccasional, but limited, personal use of technology resources is permitted provided that it is appropriate and does not interfere with the users or any other users work performance unduly impact the operation of technology resources result in any material expense to GPC violate this policy or any other GPC policy, guideline or standard violate any law or applicable regulation use storage space beyond that allocated for personal use involve the running of any personal businessEmployees relatives, associates or friends are not permitted to use GPC technology resources.Your ResponsibilitiesDo not expect electronic messages to beprivate or confidential.Do not use these systems to solicit orcommunicate in a manner which wouldviolate this or other GPC policies orprocedures, including communicatingdiscriminatory or harassing statements,pornographic material, inappropriatehumor, solicitations regarding political orcharitable matters, or for any illegalpurposes.Create messages with the generalexpectation that these may be madepublic or otherwise used in legalproceedings.Use good judgment in using thesesystems and exercise the same judgmentin creating electronic messages, as youwould use in paper documents.For further information onElectronic Communication,consult with the location HumanResources representative.CODE OF ETHICS POLICYPolicy Type: General Business Policy Date: 01.15.2019 Policy Number: 001 Page - 10 - of 21 This document is uncontrolled if printed 9. Antitrust.PolicyWe will not engage in practices that limit competition such as price fixing and division of markets, nor will we engage in practices to unlawfully restrict a competitor's opportunities.CommentsFree competition is healthy for business and good for consumers. The antitrust laws of the United States and the competition 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. As a rule, antitrust laws not only cover commercial behaviour in a particular country, but also apply to any commercial behavior even outside that country if it has a significant impact on competition. GPC will compete solely on the merits of our products and services. We will succeed by satisfying its customers needs, not by unlawfully limiting a competitor's opportunities.Because of the complexity of antitrust laws, all agreements with competitors or with other third parties, which may have a negative effect on competition, must be approved by legal counsel. Clauses which may have a negative effect on competition include exclusivity clauses pricing clauses tie-in clauses territorial restrictions price discrimination (including preferential discounts and rebates) Antitrust laws generally prohibit entering into any kind of agreement or understanding (even oral or informal) with a competitor regarding prices, costs, profits, margins, inventories, or terms and conditions of sale territories limitations on products or services production facilities, volume, or capacity market shareYour ResponsibilitiesNever agree with competitors to fixprices or divide markets.Never enter into any understandingwith a competitor that restricts eitherpartys discretion to manufacture anyproducts or provide any service, or thatlimits selling to, or buying from, a thirdparty.Never, without first consulting the ChiefGeneral Counsel, enter into anyunderstanding with a customer thatmight:1. Restrict a customers discretion touse or resell one of GPC products;2. Condition the sale of a product orservice on the customers purchaseof another product or service fromGPC.Contact the Chief General Counsel forprior approval before any meeting witha competitor. If you attend a tradeassociation meeting and competitorsare present, never discuss at themeeting or at any social gatheringprices, costs, sales, profits, marketshares, or other competitive subjects.If such matters enter into thediscussion, stop the discussion, orleave the meeting or social gathering,and notify the Chief General Counsel.Report any activities that appearcontrary to the antitrust laws to theChief General Counsel, or reportsuspected violations by calling the toll-free ethics and compliance line for yourlocation.For further information onAntitrust, consult with the ChiefGeneral Counsel.CODE OF ETHICS POLICYPolicy Type: General Business Policy Date: 01.15.2019 Policy Number: 001 Page - 11 - of 21 This document is uncontrolled if printed 9. Antitrust. (continued) customer or supplier allocation or selection distribution methods any action that affects, limits, or restricts competition bidding arrangements resale price maintenance schemes restricting products offered or tying the purchase of products to other purchases agreements to boycott, i.e. a refusal to supply or to accept delivery DONT BE MISLED into thinking that agreements are unlawful only if a written document is signed by the parties involved. If competitors make a conscious commitment to a common course of anti-competitive action, they can be in violation of competition laws.Antitrust laws prohibit the abuse of a dominant market position. The termabuse refers to situations in which dominant market power is exercised to the detriment of suppliers or customers. Marketing strategies and practices in markets in which GPC is a strong player need particular attention by the Chief General Counsel.Antitrust law may limit acquisitions, which would bring about a dominant market position and could injure competition. Moreover, notification to government authorities is required in most jurisdictions before certain acquisitions can be made. The Chief General Counsel should be involved in acquisition projects at an early stage.Contracts relating to the use of intellectual property rights (patents, trademarks, designs, copyright, know-how and trade secrets) are often subject to special rules and may therefore be critical in terms of antitrust. They need particular attention by the Chief General Counsel.CODE OF ETHICS POLICYPolicy Type: General Business Policy Date: 01.15.2019 Policy Number: 001 Page - 12 - of 21 This document is uncontrolled if printed 10. Anti-bribery.PolicyGPC must comply with all applicable laws and regulations wherever we do business. Almost every country in the world prohibits making payments or offers of anything of value to government officials, political parties, or candidates in order to obtain or retain business. These laws include the U.S. Foreign Corrupt Practice Act (FCPA), the U.K. Bribery Act of 2010 (the UK Bribery Act) and similar laws in other jurisdictions.CommentsThe Foreign Corrupt Practices Act (FCPA) 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. The FCPA also requires that GPC 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 The following actions are considered criminal by the UK Bribery Act of 2010 offering, promising or giving a bribe to another person requesting, agreeing to receive or accepting a bribe from another person bribing a foreign public official failure of a company to prevent bribery (the company is responsible for all persons associated with the company)Note: The UK Bribery Act of 2010 can apply to companies doing business in the UK, not only to acts done in the UK. Therefore, it is important that all employees, wherever located, are aware of and comply with this law. For additional information on compliance with the various Anti-Bribery laws, see the GPC FCPA & Anti-Corruption and the Fraud Policies. Your ResponsibilitiesComply with GPC procedures and actethically and with integrity.Do not make any corrupt payment,regardless of amount, to foreign officialsor personnel directly or through anintermediary.Do not use GPC assets for any unlawfulor improper use.Do not create or maintain a secret orunrecorded fund or asset for anypurpose.Comply with GPC accounting policiesand internal control procedures.Do not make any false or misleadingentries in GPC records or make anypayment on behalf of GPC withoutadequate supporting documentation.Report any suspected acts of bribery orviolations of GPC financial andaccounting policies to your supervisor orthe Chief General Counsel, or reportsuspected violations by calling the toll-free ethics and compliance line for yourlocation.For further information on thevarious Anti-Bribery laws,consult with the Chief GeneralCounsel.CODE OF ETHICS POLICYPolicy Type: General Business Policy Date: 01.15.2019 Policy Number: 001 Page - 13 - of 21 This document is uncontrolled if printed 11. 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