Ethics & Compliance Program

We are committed to ensuring a safe, ethical, inclusive, and rewarding work environment for every employee and partner.

Berry’s Behaviors

Behaviors are the way that we act as a Company, as employees and as community partners.

Berry's official Behaviors are:

  • 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 of 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.

Our Mission

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.

Oversight & 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." - Tom Salmon, Chairman & CEO.

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Global Code of Business Ethics

Our Global Code of Conduct 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.

View Policies

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.

Training & Communications

We engage and develop our employees on the risks that most impact their day-to-day responsibilities. 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.

Our Values

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 by providing the highest quality products and services to our customers. We believe in 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 our Company.

Safety
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.

 

Employee Testimonial

"We are building an ethical culture where team members live our Values and are comfortable Speaking Up, if they have concerns. A strong ethical culture supports our internal controls and drives an effective Corporate Governance program."

Jason Greene
Chief Legal Officer | Evansville, IN | USA

"Our leaders make decisions everyday based on our Values and ethics. This provides a clear path and trustable environment for each of us to do our jobs and be proud of it."

Darci Padilha
VP Human Resources | São José Dos Pinhais, Brazil

"Ethics is part of our DNA. We maintain our industry leading reputation by generating results in line with our Values and Behaviours, including respect for human rights and proper working conditions and honoring our social and environmental responsibilities."

Søren Rohleder
CEO Berry Superfos | Hamburg, Germany

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.

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