RIGID INDUSTRIAL PACKAGING & SERVICES
and Packaging Accessories, including Tri-Sure® Closures; Container Life Cycle Management;, EarthMinded® Life Cycle Services; Delta Companies Group
FLEXIBLE PRODUCTS & SERVICES
As an employee of Greif or its subsidiaries (“Greif”), you are subject to Greif’s Code of Business Conduct and Ethics. Among other matters, the Code requires that all employees “Comply with all laws, rules and regulations.” Greif conducts business in more than 50 countries around the world and our employees are citizens of many different countries. Consequently, our business is subject to the antitrust and competition laws of many countries, provinces, states and other government organizations. It is each employee’s responsibility to know and understand the legal requirements applicable to his or her job.
The laws of the United States frequently extend to the operations of Greif and its subsidiaries and affiliates around the world, as well as the activities of its employees regardless of location. For that reason and to facilitate administration and compliance and for other reasons, in addition to complying with all applicable national antitrust or competition laws, all Greif employees must also observe the antitrust laws of the United States. Always remember that violations of Greif policy and the law can subject you and the Company to severe criminal penalties and monetary damages.
The U.S. Department of Justice, the European Commission and other national anti-trust/competition authorities have been vigilant in investigating and charging companies with antitrust or competition-related crimes. These cases have shown that the alleged actions of a few individuals can have a dramatic adverse effect on their employer company and other companies in the industry. It is therefore in the interest of Greif to adopt on a worldwide basis effective antitrust/competition compliance practices.
The concepts set out in this Policy are generally stricter than what is required by law. This is in recognition of the fact that antitrust/competition investigations and lawsuits, even if without merit, are often brought on mere appearances of impropriety, and are extraordinarily expensive, time-consuming, and disruptive.Since these Guidelines are necessarily general in nature and cannot address in detail every situation that may arise, consultation with the Greif Legal Department is strongly recommended when analyzing specific issues and circumstances.
Some public communications by companies, in press releases, on web sites or otherwise, have the potential to be challenged as improper communications between competitors.It is therefore important when making such statements to consider whether the language used or the information conveyed could be characterized as “signaling” or an “invitation to collude.”
To minimize the risk of antitrust/competition investigations and litigation and the allegation of inappropriate competitor communications, take the following precautions.Deviations from these precautions may be appropriate in particular situations after review and approval by the Greif Legal Department.
Presentations to analysts and investors may require discussion of subjects such as prices or trends, capacity, operating rates, costs, inventory, backlogs, or market conditions.Review by the Greif Legal Department is strongly recommended in such situations to ensure that the communication is framed in a way that cannot be portrayed as “signaling” or an “invitation to collude” and is limited to information necessary to meet Greif’s disclosure obligations to the investment community consistent with SEC requirements.
Certain announcements to third parties regarding industry actions could be challenged as an illegal call for competitors to make collective business decisions. For example, do not say things such as:
“The industry needs to show some discipline to get prices up.”
“We all need to recognize that there is too much capacity and we need to do something about it.”
“No one is making money at today’s prices.”
Communications regarding competitively sensitive topics such as pricing, output, and capacity should clearly document the unilateral, legitimate reasons why particular actions were taken. For example, if a price increase was justifiable due to increased costs or increased demand, that information should be stated.
The following guidelines are suggested for communications with publications that conduct market surveys and report estimates of current market prices:
Communications of any kind among competitors, including benchmarking, can generate a perception that competitors misuse these exchanges to reach and enforce agreements on, for example, price, production, or allocation of markets. In Australia for instance, the Australian Competition and Consumer Commission is likely to view benchmarking as an attempt to fix prices. While limited benchmarking programs can enhance efficiencies and reduce costs, such programs should be approved by the Greif Legal Department in advance and should involve careful planning, control and execution.
To minimize the antitrust risk and the perception of inappropriate competitor communications, the following precautions are recommended:
Company-to-company interactions and formal or informal information exchanges may be portrayed as collusion to set prices or other anticompetitive behavior.To avoid this misperception, the following precautions are recommended:
Prices
Profit margins
Bids (or intent to bid or not to bid)
Credit standards
Discounts
Inventory levels
Rebates
Terms of sale
Pricing plans
Changes in operating rates
Expansion and contraction plans
Facility closures
Changes in operating schedules
Capacity or output
Selection or classification of customers
Costs
Markets, marketing strategies or plans
Dividing markets, geographic territories or customers
Boycotting any customer, supplier or other competitor
Termination of a customer relationship
In the case of labor costs in multi-employer bargaining situations, consult with the Greif Legal Department.
Two basic principles should be followed.
Any communication with a competitor/supplier or competitor/customer must be in the context of a legitimate, good faith interest in buying or selling. This does not mean that every conversation must result in a purchase or sale. For example, company X may call supplier Y to explore a purchase, but learns that there is no product availability or the price isn’t right. However, the context is that company X had a genuine, legitimate interest in buying. This is to be contrasted with a “dummy” call where there is no interest in buying, but the call is made primarily to obtain market information.
Assuming that the first principle is met, the conversation should be strictly limited to matters directly necessary to complete the transaction at hand. Never exchange “competitive intelligence” during these discussions. This includes discussions about general market trends, supply or demand, pricing, or other competitors that is not related to bona fide needs for the transaction at hand.
No employee may join any trade association, multi-employer group or other organization without approval by an officer of Greif or that employee’s Business Unit manager.
Attendance by an employee at a trade show, trade association meeting and/or industry-wide meeting or conference must be reviewed by an officer of Greif or that employee’s Business Unit manager for appropriateness. Particular care should be taken if meetings involve personnel with pricing authority. Industry pricing, market trends and other sensitive competitive topics should never be mentioned or discussed in any fashion. If pricing or any inappropriate topic is raised by a competitor, Greif personnel should object and, if necessary, leave immediately. The Greif Legal Department should be contacted immediately whenever improper matters are discussed and provided with any relevant documents.
Special care should be given when making presentations at trade association or industry meetings and conferences or trade shows, especially on topics with competitive sensitivity (for example, prices or trends, capacity, operating rates, costs, or market conditions). If the presentation is on a topic of competitive sensitivity, that presentation should be reviewed by the Greif Legal Department and the legal counsel for the group producing the event.
The actions of agents can create the risk of antitrust/competition proceedings. Greif should encourage its agents to adopt suitable antitrust compliance guidelines and should consider the existence and effectiveness of such guidelines in evaluating the performance of their agents. In the case of agents that serve multiple companies in the same industry, such compliance guidelines should specifically address the special challenges of such relationships, including safeguards against the flow of information among competitors that might be portrayed as reducing competition.
This Policy is focused primarily on conduct and circumstances that relate to price fixing, but all employees must remain mindful of and comply with laws pertaining to price discrimination (in the U.S., this is called the Robinson-Patman Act), abuse of dominant position, refusal to deal or boycotting of customers, product tying arrangements, exclusive dealing arrangements and other applicable laws. You should always consult with the Greif Legal Department with any questions regarding these matters and in any situation that appears to have the potential to violate antitrust or competition laws.
Revised: May 1, 2011
GREIF PAPER PACKAGING AND LAND MANAGEMENT
As an employee of Greif, Inc. or its subsidiaries (“Greif”), you are subject to Greif’s Code of Business Conduct and Ethics.Among other matters, the Code requires that all employees “Comply with all laws, rules and regulations”.While all laws are important, the United States laws relating to antitrust, and in particular price-fixing, merit particular attention given the history of the paper and timber industries and the consequences of violations.Always remember that violations of Greif policy and the law can subject you and the Company to severe criminal penalties and monetary damages. It is each employee’s responsibility to know and understand the legal requirements applicable to his or her job.
The U.S. Department of Justice has been vigilant in investigating and charging companies with antitrust crimes.These cases have shown that the alleged actions of a few individuals can have a dramatic adverse effect on their employer company and other companies in the industry.It is therefore in the interest of Greif to adopt effective antitrust compliance practices.
The concepts set out in this Policy are generally stricter than what is required by law.This is in recognition of the fact that antitrust investigations and lawsuits, even if without merit, are often brought on mere appearances of impropriety, and are extraordinarily expensive, time-consuming, and disruptive.Since these Guidelines are necessarily general in nature and cannot address in detail every situation that may arise, consultation with the Greif Legal Department is strongly recommended when analyzing specific issues and circumstances.
Some public communications by companies, in press releases, on web sites or otherwise, have the potential to be challenged as improper communications between competitors.It is therefore important when making such statements to consider whether the language used or the information conveyed could be characterized as “signaling” or an “invitation to collude.”Particular care should be taken when making announcements concerning competitively sensitive matters such as price changes and downtime.
To minimize the risk of antitrust investigations and litigation and the allegation of inappropriate competitor communications, take the following precautions.Deviations from these precautions may be appropriate in particular situations after review and approval by the Greif Legal Department.
To avoid the allegation that public disclosures of future downtime are signaling anticompetitive behavior, the following precautions are recommended:
Presentations to analysts and investors may require discussion of subjects such as prices or trends, capacity, operating rates, costs, inventory, backlogs, or market conditions.Review by the Greif Legal Department is strongly recommended in such situations to ensure that the communication is framed in a way that cannot be portrayed as “signaling” or an “invitation to collude” and is limited to information necessary to meet Greif’s disclosure obligations to the investment community consistent with SEC requirements.
Certain announcements to third parties regarding industry actions could be challenged as an illegal call for competitors to make collective business decisions. For example, do not say things like:
“The industry needs to show some discipline to get prices up.”
“We all need to recognize that there is too much capacity and we need to do something about it.”
“No one is making money at today’s prices.”
“People need to take downtime if we are going to get out of the hole we are in.”
The following guidelines are suggested for communications with publications that conduct market surveys and report estimates of current market prices, such as Pulp & Paper Week and Random Lengths:
Communications of any kind among competitors, including benchmarking, can generate a perception that competitors misuse these exchanges to reach and enforce agreements on, for example, price, production, or allocation of markets.While limited benchmarking programs can enhance efficiencies and reduce costs, such programs should be approved by the Greif Legal Department in advance and should involve careful planning, control and execution.
To minimize the antitrust risk and the perception of inappropriate competitor communications, the following precautions are recommended:
Appendix A contains the AF&PA Statement of Policy and Procedures Regarding Statistical Reports.Variations from these parameters may be appropriate in particular situations after review and approval by the Greif Legal Department.The AF&PA statistics program has undergone rigorous antitrust counsel review and may be a useful reference when Greif considers participation in benchmarking or information-sharing programs sponsored by other trade associations.
Company to company interactions and formal or informal information exchanges may be portrayed as collusion to set prices or other anticompetitive behavior.To avoid this misperception, the following precautions are recommended:
PricesProfit Margins
Bids (or intent to bid or not to bid)
Credit standards
Discounts
Inventory levels
Rebates
Terms of sale
Pricing plans
Changes in operating rates
Expansion and contraction plans
Facility closures
Changes in operating schedules
Capacity or output
Downtime or turnaround plans
Costs
Selection or classification of customers
Markets, marketing strategies or plans
Dividing markets, geographic territories or customers
Boycotting any customer, supplier or other competitor
Termination of a customer relationship
In the case of labor costs in multi-employer bargaining situations, consult with the Greif Legal Department.
Any communication with a competitor/supplier or competitor/customer must be in the context of a legitimate, good faith interest in buying or selling. This does not mean that every conversation must result in a purchase or sale.For example, company X may call supplier Y to explore a purchase, but learns that there is no product availability or the price isn’t right.However, the context is that company X had a genuine, legitimate interest in buying.This is to be contrasted with a “dummy” call where there is no interest in buying, but the call is made primarily to obtain market information.
Assuming that the first principle is met, the conversation should be strictly limited to matters directly necessary to complete the transaction at hand.Never exchange “competitive intelligence” during these discussions.This includes discussions about general market trends, supply or demand, pricing, or other competitors that is not related to bona fide needs for the transaction at hand.
The actions of agents can create the risk of antitrust litigation, both criminal and civil.Greif should encourage its agents to adopt suitable antitrust compliance guidelines and should consider the existence and effectiveness of such guidelines in evaluating the performance of their agents.In the case of agents that serve multiple companies in the same industry, such compliance guidelines should specifically address the special challenges of such relationships, including safeguards against the flow of information among competitors that might be portrayed as reducing competition.
This Policy is focused primarily on conduct and circumstances that relate to price fixing, but all employees must remain mindful of and comply with laws pertaining to price discrimination (known as the Robinson-Patman Act), refusal to deal or boycotting of customers, product tying arrangements, exclusive dealing arrangements and other applicable laws.You should always consult with the Greif Legal Department with any questions regarding these matters and in any situation that appears to have the potential to violate antitrust laws.
Statistical reporting is one of the core functions of a trade association.AF&PA’s statistical reports provide substantial benefits to association members by providing accurate and timely information that is highly useful for sound business planning.At the same time, under some circumstances statistical reporting programs can give rise to antitrust concerns.Accordingly, these guidelines are designed to ensure that AF&PA’s statistical reporting system does not create antitrust problems.
Revised May 1, 2011
Control No: LEG 105
Policy Name: Insider Trading Policy
Responsible Corporate Function/Business Segment: Legal
Effective: February 11, 2019
Coverage: Global – All employees, which includes temporary employees, contractors and subcontractors
Policy Overview & Objective
It is illegal under the securities laws of the United States for anyone to purchase or sell securities of a company while aware of, or in possession of, material non-public information about that company. It is also illegal to disclose material non-public information to others who could then trade in those securities. This includes Greif and public companies with whom Greif does business. The objective of this Policy is to protect Greif and its employees by establishing a process to guide Greif employees in the legal trading of Greif securities or the securities of Greif’s business partners.
The Policy
This Insider Trading Policy (“Policy”) provides guidelines with respect to trading in Greif securities and the handling of confidential information about Greif and its subsidiaries or other companies with whom Greif conducts business. This Policy was adopted to promote compliance with the securities laws of the United States and to assist our directors, officers and employees in complying fully with the law when trading in securities of Greif or of another company.
It is illegal under United States securities laws: • To trade in Greif securities (defined below) while aware of, or in possession of, material non-public information about Greif; • To trade in the securities of a company with whom Greif does business (“business partners”) while aware of, or in possession of, material non-public information about such company; and • To disclose material non-public information to others who could then trade in Greif securities or the securities of Greif’s business partners. That type of disclosure is sometimes referred to as “tipping.” |
This Policy applies to (Greif and its subsidiaries): • All Members of the Board of Directors • All Officers • All Employees • Others as determined by Greif (i.e. joint venture partners, contractors or consultants) • Family members within your household (described below) • Others who live within your household (described below) • Others who are subject to your control or influence (described below) • Entities who are subject to your control or influence (described below) |
II. Individual Responsibility
Each individual subject to this Policy has an ethical and legal obligation to protect and maintain the confidential information of Greif and to not engage in transactions in Greif securities while in possession of material non-public information. Each individual (including family members and any controlled entities) is responsible in both his or her personal and professional capacity to act in a manner consistent with this Policy. In all cases, the responsibility for determining whether an individual is in possession of material nonpublic information rests with that individual, and any action on the part of Greif or any of our directors, officers or employees pursuant to this Policy (or otherwise) does not in any way constitute legal advice or insulate an individual from liability under applicable U.S. securities laws. This Policy is intended to help prevent even the appearance of improper conduct on the part of directors, officers and employees of Greif or anyone otherwise associated with Greif. This Policy should be read in conjunction with Greif’s Code of Business Conduct and Ethics. Any questions regarding this Policy in general or the application of this Policy to a particular case should be directed to Greif’s General Counsel.
NO director, officer or employee of Greif who is aware of, or in possession of, material non-public or “inside” information regarding Greif, may directly or indirectly through family members or other persons or entities:
In addition, NO director, officer or employee who is aware of, or in possession of, material non-public information of any other publicly held company with which Greif does business (including a customer or supplier) may trade directly or indirectly in that company’s securities or pass or “tip” that information to others (except for persons within Greif who have a business “need to know”) or otherwise use that information for personal gain until the information becomes public or is no longer material. |
Information is considered “material” if a reasonable investor would consider it important in deciding to buy, hold or sell securities of Greif. Any information that could reasonably be expected to affect the price of Greif’s stock is material, whether it is positive or negative. There is no “bright line” test for assessing materiality. Rather, materiality is based on an assessment of all of the facts and circumstances, and is often evaluated by enforcement authorities with the benefit of hindsight. Examples of material information include, but are not limited to:
Non-public information is information that has not yet been made public by Greif. Information is only considered public when Greif makes an official announcement and the investing public has had an adequate opportunity to see or hear and digest such information. As a result, information is not generally deemed public until the third business day after the information has been released to the public.
IV. Consequences of Insider Trading
The consequences of an insider trading violation can be severe:
A director, officer or employee who tips information to a person who then trades is subject to the same penalties as the tippee, even if the director, officer or employee did not trade and did not profit from the tippee’s trading.
2. Control Persons. Greif and its supervisory personnel are subject to the following penalties if they fail to make appropriate steps to prevent illegal insider trading:
3. Company Imposed Disciplinary Actions. Greif may impose disciplinary actions against any violator, up to and including termination of employment for cause. In addition, a violator may be subject to civil or criminal penalties, as well as serious damage to his or her reputation and career. Transactions that may be necessary or justifiable for personal reasons (such as the need for funds for an emergency expenditure) do not excuse noncompliance with this Policy.
1. Who Requires Pre-Clearance to Trade?
Individuals who are notified by the Greif General Counsel and listed by name on the “Insider Trading List” are prohibited from trading in Greif securities along with their immediate family members and controlled entities, without:
2. How to obtain Pre-clearance.
If you are subject to the Insider Trading List, you should contact the Greif General Counsel, by telephone, voicemail, e-mail, or facsimile, by 3:00 p.m. EST at least two (2) business days in advance to pre-clear a proposed transaction. If the General Counsel is not available, you may contact the Deputy General Counsel or Corporate Financial Controller or Treasurer. If you communicate with selected approvers above other than by directly in person or telephone discussion, you must receive an acknowledgement that your communication was received. In any event, the General Counsel will determine whether the transaction is permitted by this Policy and will assist you in complying with any applicable reporting requirements.
These procedures are implemented to assist in the prevention of inadvertent violations and to avoid the appearance of improper transactions that may result, for example, if a director, officer or employee engaged in a trade even though unaware of a pending major development.
3. Other Pre-Clearance Considerations.
4. When is the Trading Window Open?
(a) certain developments relating to Greif that are not yet disclosed to the public; or (b) other reasons deemed appropriate. Remember: Even if the trading window is open, you cannot trade if you are personally aware of material non-public information. |
5. Additional Pre-Clearance Requirements for Board of Directors and Section 16 Officers.
Directors and Section 16 Officers of Greif are required by the Securities and Exchange Commission to report all trades of Greif securities within 48 hours of the transaction. The Greif Legal Department will assist those individuals with the required filings. The pre-clearance requirements in this Policy are intended to facilitate compliance with these reporting requirements by tracking securities transactions by directors and Section 16 Officers.
6. Transactions by Family Members and Controlled Entities.
Those individuals who have material non-public information and/or listed on Greif’s Insider Trading List have a responsibility to inform that this Policy also applies to:
You are responsible for the transactions of these other persons and entities and therefore should make them aware of the need to confer with you before they trade in Greif securities. For purposes of this Policy and U.S. securities laws, you should treat all transactions in Greif securities by these other persons and entities as if the transactions were from your own account.
2. Dividend Reinvestment Plan. This Policy does not apply to ongoing purchases of Greif securities under the dividend reinvestment plan resulting from your reinvestment of dividends paid in Greif stock. However, this Policy does apply to certain elections you may make under the dividend reinvestment plan, including:
3. Restricted Stock/Performance Awards. This Policy does not apply to the vesting of restricted stock, or the exercise of a tax withholding right pursuant to which you elect to have Greif withhold shares of stock to satisfy tax withholding requirements upon the vesting of any restricted stock. However, this Policy does apply to any market sale of restricted stock.
4. Stock Options. This Policy does not apply to the exercise of an employee stock option acquired pursuant to the plan, to the exercise of a tax withholding right pursuant to which a person has elected to have Greif withhold shares subject to an option to satisfy tax withholding requirements. However, this Policy does apply to any sale of Greif securities as part of a broker-assisted cashless exercise of an option, or any other market sale for the purpose of generating the cash needed to pay the exercise price of an option.
5. Special 401(k) and Pension Plan Blackout Periods. This Policy does apply to purchase, sale or transfer of Greif securities in the Greif 401(k) or Greif defined benefit pension plan (or the creation of a Rule 10b5-1 trading plan) during a “fund blackout period.” A fund blackout period exists whenever 50% or more of the participants in a plan that invests or permits investments in Greif securities are unable to conduct transactions in their accounts for more than three (3) consecutive days. These blackout periods typically occur when there is a change in the trustee, record keeper or investment manager for a retirement plan. You will be contacted when these or other restricted trading periods are instituted from time to time.
VII. Rule 10b5-1 Trading Plans
Notwithstanding the general prohibition against trading while aware of, or in possession of, material non-public information, directors, officers and those listed on the Insider Trading List may execute trades in Greif securities, even outside of the trading window period, if such trades are pursuant to an approved prearranged written Rule 10b5-1 trading plan. Rule 10b5-1 trading plan is a trading contract or set of instructions that meets the following requirements:
You should contact the General Counsel if you desire to enter into such a trading plan or if you have any questions.
VIII. Prohibited Transactions
Directors, officers and employees cannot engage in short-term or speculative transactions in Greif securities, which includes:
Only the Chairman, Chief Executive Officer, Chief Financial Officer, General Counsel, Vice President of Investor Relations, Director of Communications and any other representative of Greif designated by the Chief Executive Officer may make communications and presentations on Greif’s behalf to the media and the investment community. If an inquiry is made, refer the person making the inquiry to Greif’s Director of Communications or the General Counsel.
This Policy continues to apply to your transactions in Greif securities even after your service with us ends. If you are aware of material non-public information when your service with us ends, you may not trade in Greif securities until that information has become public or is no longer material. |
Any questions regarding this Policy in general or the application of this Policy to a particular case should be directed to the Greif General Counsel.
References
Code of Business Conduct and Ethics Policy
Greif Alert Line
Addendum
None
In recent years, global awareness of the significant adverse impacts resulting from mineral mining and extraction operations in certain conflict-affected and high-risk areas of the world has increased. Tin, tantalum, tungsten, their ores and mineral derivatives, and gold (“conflict minerals”) emanating from the Democratic Republic of Congo (DRC) and adjoining countries have been identified as products of such mining operations that can make their way into the global manufacturing supply chain. Armed groups engaged in mining operations in the DRC have been linked to human rights abuses and violations of national or international law, and are believed to be using the proceeds of the mining operations to fund conflict in the country. As required by the Dodd-Frank Wall Street Reform and Consumer Protection Act, the United States Securities and Exchange Commission (SEC) has issued regulations that require U.S. companies, including Greif, Inc., to report on the use of conflict minerals in their products.
Greif is directed by the core principles of our business, called the Greif Way, and is committed to ethical business practices and compliance with all applicable laws and regulations. We are therefore dedicated to working with our customers and suppliers to source in a responsible manner the materials we use in manufacturing our products. To comply with the SEC reporting regulations relating to conflict minerals, we have reviewed and will continue to review our use of these minerals in our products and our global supply chain management system in accordance in all material respects with the general principles set forth in the OECD’s Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “Guidance”).
Consistent with the Guidance, we will work to:
As part of our supply chain management system, we will require that our suppliers:
The process of tracing conflict minerals through any supply chain is complicated and time-consuming. However, Greif is committed to working with our customers and our suppliers to ensure effective implementation of this legislation and its related regulations.
As required by this law, Greif published a report on the measures it is taking to prevent and eliminate forced labor in our direct supply chain.
On and after Jan. 1, 2012, certain companies manufacturing or selling products in the State of California are required to disclose their efforts, if any, to address the issue of slavery and human trafficking, per the California Transparency in Supply Chains Act of 2010. This law requires each of those companies to provide information disclosing their efforts to eradicate slavery and human trafficking from its direct supply chain, thereby allowing consumers to make informed choices regarding the products they buy and the companies they choose to purchase from.
Slavery and human trafficking can take many forms, including forced labor and child labor.
Greif has addressed these issues in its supply chain in many ways. For example:
Greif, Inc. (NYSE: GEF, GEF.B) is a global leader in industrial packaging products and services and is pursuing its vision to become the world’s best performing customer service company in industrial packaging. The company produces steel, plastic, fibre, flexible, corrugated, and reconditioned containers, intermediate bulk containers, containerboard and packaging accessories, and provides filling, packaging and industrial packaging reconditioning services for a wide range of industries. Greif also manages timber properties in the south eastern United States. The company is strategically positioned with more than 200 operating locations in more than 40 countries to serve global as well as regional customers.
Our Code of Business Conduct and Ethics requires compliance with all rules, regulations and laws. Greif has adopted several compliance policies to provide assistance in understanding and following the requirements of some of the more complicated laws. These compliance policies include the following:
Anti-Bribery Compliance Policy:
Economic and Trade Sanctions Policy:
Antitrust Guidelines - Rigid Industrial Packaging & Services, Flexible Products & Services
Our Code of Business Conduct and Ethics is part of The Greif Way and provides guidance for ethical decision making and behavior to our Board of Directors, officers and all employees.
Greif’s suppliers are essential. They provide the materials and services that keep our businesses running. As such, we treat our suppliers as vital partners to our business. In exchange, we expect our suppliers to display similar values in the workplace, the marketplace and the global community.
Standard Terms and Conditions of Purchase concerning the purchase of goods and services by Greif and its subsidiaries and affiliates.
Greif is directed by the core principles of our business, called the Greif Way, and is committed to ethical business practices and compliance with all applicable laws and regulations. We are therefore dedicated to working with our customers and suppliers to source in a responsible manner the materials we use in manufacturing our products.
As required by this law, Greif published a report on the measures it is taking to prevent and eliminate forced labor in our direct supply chain by Jan. 1, 2012.