Silgan Closures/Plastics Supplier Requirements

Code of Ethics

Silgan Closures/ Plastics (Silgan)maintain a valuable reputation in the business community for honesty and fair dealing by acting ethically and in accordance with the laws applicable to its business. Our commitment to ethical business practices supports our commitment to quality and integrity in the business world. Silgan’s expectation is that each of its suppliers will likewise conduct its business in a legal and ethical manner complying with all applicable federal and state laws and regulations.

Labor Standards
The Supplier must ensure that it meets all applicable Federal, State and Local labor laws, including:

• Anti-slavery, child labor and human trafficking laws.
• Industry standards pertaining to number of hours and days worked
• Applicable laws and binding collective agreements (where applicable), including those pertaining to overtime work and other premium pay arrangements.
• Non-discriminatory hiring and employment practices on the grounds of criteria such as race, color, religion, gender, age, physical ability, national origin, or sexual preference.

Safety and Health
The Supplier shall provide employees with safe and healthy working conditions. Facilities must be constructed and maintained in accordance with applicable standards set by Federal, State, and City codes and ordinances.

Sustainability/Environment
At Silgan, our goal is to provide a positive environmental impact by seeking out sustainable, value-creating opportunities in our manufacturing operations and the products we produce. As such, we expect our suppliers to also strive to use their natural resources effectively and responsibly by managing energy use, reducing waste, and recycling where possible.

Code of Federal Regulations

The Supplier shall comply with all applicable parts of the Code of Federal Regulations.
Articles will not, when shipped, be adulterated or misbranded within the meaning of the Federal, Food, and Drug or Cosmetic Act, or any applicable state law in which the definitions of misbranding are substantially the same as those contained in the Federal, Food, Drug and Cosmetic Act as amended as of this date.

Quality System

The Silgan Quality Philosophy can be summarized as follows:

• We define quality as conformance to all Silgan requirements: performance, schedule and cost.
• We focus on prevention rather than correction.
• We establish the responsibility for quality with each individual and organization (internal/external).
• We obtain quality by seeking continuous improvement, minimizing deviations from requirements.

The Supplier shall have a documented Quality System which Complies to Industry Standards, such as ISO9001-2008, GFSI, QMA-Safe, etc.

Silgan Supplier Assessment

Silgan will monitor its Suppliersvia the following tools:

• Monitor supplier through verification of incoming primary material
• Periodic auditing of key incoming materials per Silgan requirements
• Surveillance Audits or on site visits
• OTIF (On time In Full – right quality, right time, right weight), where applicable
• Supplier Performance Evaluation metrics and scorecards, where applicable

The distribution of this document to Suppliers is dependent upon the criticality of product purchased and other factors determined by Silgan.