Significance

Importance To Berry Global and our Stakeholders

Ethical business practices are the cornerstone of responsible business conduct. By conducting business ethically, we help mitigate risks, foster a thriving work environment, and attract high-caliber talent, safeguarding our reputation and underpinning our company's long-term viability and financial stability.

Furthermore, by adhering to ethical and environmental regulations, we demonstrate our dedication to sustainable development, social responsibility, and environmental progress while eliminating non-compliance risks, financial penalties, legal repercussions, and reputational harm.

Our Customers: Customers value businesses that demonstrate integrity and environmental responsibility, which is why we are committed to driving long-term sustainability across all aspects of our business through our robust ethics and compliance program.

Our Investors: We are expected to uphold the highest ethical standards and comply with environmental regulations so as not to damage the value of our business.


Our Approach

Building an ethical culture is a differentiator–whether retaining top talent, becoming a destination workplace, being agile, demonstrating resiliency or satisfying our customers. Berry believes companies that do the right thing for the right reasons will outperform their peers. Therefore, as an organization committed to growing organically, we have placed the highest emphasis on building a OneBerry ethical culture and maintaining ethical and environmental compliance. Our Global Ethics & Compliance program protects our people, assets, partners, brand, and reputation by promoting an ethical culture, providing tools to do the right thing, creating a positive, safe, and inclusive work environment, and ensuring adherence to all local laws and regulations. Learn more about our ethics and compliance policies.

We are committed to ensuring a safe, ethical, inclusive, and rewarding work environment for every employee and partner. We have four key values: Partnerships, Excellence, Growth, and Safety, and we believe ethics and compliance is about making our values come to life. These values embody our policies and procedures, inform our decision-making process, protect our industry-leading reputation, and are the foundation for our ethical culture. 

Partnerships: We recognize the importance of strong, sustainable partnerships throughout all aspects of our business – we view our employees, customers, suppliers, and communities as our partners. 

Excellence: We pursue excellence in all that we do by optimizing our processes, enhancing our sustainability initiatives, and providing the highest quality products and services to our customers. We believe in providing continuous training and development for our employees so that we can deliver excellence to our customers. 

Growth: Strategic growth is imperative for our business. Growth comes in many forms– financial growth, customer growth, employee growth and development, product growth and innovation, and the global growth of Berry.  

Safety: This is our number one value. We relentlessly pursue safety in all we do. We maintain high standards to ensure our facilities are safe and environmentally conscious. 

Our Values help guide our behaviors of remaining United, Focused, Agile, and Accountable, which reflect the way that we act as a company, as employees, and as community partners. 

United: We operate as a team – One Berry. We understand the importance of diversity in our team members and appreciate the unique talents and perspectives that each of us brings to our organization. 

Focused: We have a clear focus on creating a strong future for all our stakeholders - our company, our customers, our employees, our shareholders, and the communities in which we operate. 

Agile: We move in a quick and intentional manner. We encourage our team members to be action-oriented and to deliver the best service for our customers. This will allow us to advance our performance, products, services, and culture. 

Accountable: We know that our success is driven by our ability to honor the commitments we make. We will conduct our business with integrity and in accordance with the highest ethical, moral, and legal standards. 


Highlights and Target Progress

Target 2023 Progress
To promote a Speak Up culture, decrease the rate of anonymous Ethics Helpline reports each year.
In 2023, the rate of anonymous Ethics Helpline reports increased by 9% which is comparable, although slightly larger, to the 6% increase for organizations across all industries. We will continue to strengthen and promote our Speak Up culture and non-retaliation commitment to reduce this rate.
100% of employees to complete Global Code of Ethics training We had a greater than 98% Global Code of Ethics training completion rate in 2023.

Key Metrics

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

Ethics and Compliance

  2023
Ethics Helpline Total Reports Anonymity Rate (%)¹ Average days to close
Ethics Helpline Process 301
71% 24
Compliance Training (Full Time Employees) Participants Completions Completion Hours
Total Assigned Compliance 28,673 78,418 27,090
  Courses Completed Completion % Completion Hours
Compliance Short: Antitrust 9,605 98.7%  1,154 
Compliance Short: Anti-bribery 9,609
98.8%
1,170
Compliance Short: Insider Trading 9,580
 98.7% 1,586
Compliance Short: GDPR  9,579  98.7% 1,222
Cybersecurity Awareness Training  11,826  99.7%  10,145
Global Code of Business Ethics Training  28,219  98.4% 11,813
Compliance Training  (Part Time Employees/Contractors)
Participants  Completions  Completion Hours 
 Total Assigned Compliance  893  2,309 771
  Courses Completed Completion % Completion Hours 
Compliance Short: Antitrust 292 96.7% 33
Compliance Short: Anti-bribery 292
96.7%
33
Compliance Short: Insider Trading 289
96.7%
46
Compliance Short: GDPR 290
97.0%
36
Cybersecurity Awareness Training 331
99.7%
269
Global Code of Business Ethics Training 815
91.3%
354
Code of Conduct
Percentage of Employees
Berry Code of Conduct Acknowledgement 98%

Environmental Compliance

  2021 2022 2023
Environmental Auditing Number of Facility environmental audits completed by Division
Consumer Packaging International (CPI) 6
7
50
Consumer Packaging North America (CPNA) 6
7
7
Flexibles 5
8
7
Health, Hygiene & Specialties (HHS) 6
7
6
Berry Global Total 23 29 70
Environmental Management Systems Number and Percentage of Facilities holding Environmental Certification
Total Percentage Total Percentage Total Percentage
ISO 14001 76
27% 77 29% 70 29%
ISO 50001 40
14% 46 17% 41 17%
Environmental Sanctions Significant Fines and/or Non-Monetary Sanctions for Environmental Non-Compliance²
Number of incidents 0 0 1
Total Dollar ($) amount of fines $0 $0 $17,500
Number of incidents in relation to water withdrawals or wastewater discharge 0 0 1
Total Dollar ($) amount of water-related fines $0 $0 $17,500
1. 100% of reports had the option of remaining anonymous. We track this metric to understand the % of employees that are comfortable revealing their identity because they believe there will not be retaliation.
2. Significant refers to fines and penalties greater than $10,000 USD (or equivalent when converted from local currency). Incidents are reported in the year in which the fines and/or sanctions are settled to avoid inaccurate figures being reported.



Key Strategies

Business Ethics 

Infographic to show 80,000+ ethics and compliance courses completed, 27,500 hours of trainingPer our Employee Handbook and Global Code of Business Ethics, we are firmly committed to non-discrimination and anti-harassment. To further increase our transparency, we created a standalone, public Non-Discrimination & Anti-Harassment Policy. This policy covers sexual and non-sexual harassment and reiterates our commitment to Speak Up without fear of retaliation when someone has witnessed or experienced such behavior. We also provide annual training for all our team members on harassment and discrimination and the consequences of such behavior and provide additional guidance and responsibilities to our management teams.

Berry has dedicated significant attention to building internal controls, training, and communication regarding anti-competitive behavior. We added to these efforts by rewriting our Global Competition Policy and updating the Fair Competition section of the Global Code of Business Ethics. Both values-based documents highlight the importance of acting with honesty, integrity, and transparency, supporting the identification of red flags, and providing guidance if a competitor attempts to discuss sensitive information.  

To reinforce this message, we provide training on anti-competitive behavior, translated into key languages, for all office team members. While we have not had a confirmed case of anti-competitive behavior, we encourage our team members to Speak Up 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, Chairman & 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 will include 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, including fair competition, insider trading, global anti-bribery, 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 Global - The Ethics Helpline InformationBerry 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.

QR code for Ethics HotlineAt 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.

In FY23, companies across all industries experienced a significant increase in the number of helpline reports by approximately 15% along with a 6% increase to the rate of anonymous reporting. Our number of helpline reports also increased by this margin with a slightly larger increase (9%) in anonymous reporting. In response to this global trend facing all organizations, we remain committed to a culture and process where employees feel safe to identify when using the helpline to report a concern.

Berry Global - Ethics Helpline Reports Anonymous Rate ChartAs 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 

We have a responsibility to ensure all operations across our facilities conform to and comply with all local, regional, and global environmental regulations and eliminate instances of environmental-related non-compliance. Our environmental management program allows us to continually track, manage, and report our environmental performance, monitor environmental regulations to maintain compliance, and benchmark against the environmental goals in our Impact 2025 strategy.

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. In 2023 we had one fine for environmental non-compliance totaling $17,500. The site at which this incident occurred has since been closed and is no longer under Berry’s control.

Environmental Management Systems 

Environmental Management Systems Chart - BerryWe 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.

ISO Certifications Infographic - BerryTo 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 2023, 77 facilities (29% of total facilities) held the ISO 14001 environmental management certification, and ISO 50001 energy management certifications were held by 41 facilities (17%).

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 2023, internal and external environmental audits were completed across 70 of our facilities, up from 29 in 2022.


Disclosures 

Contribution to the Sustainable Development Goals (SDGs)

SDG 8: Decent Work and Economic GrowthSDG 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 ProductionSDG 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 WaterSDG 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 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: December 14th 2023