Slavery and Human Trafficking Memo

Introduction

This Slavery and Human Trafficking Statement, dated as of August 19, 2019, is presented to comply with the California Transparency in Supply Chains Act of 2010 (the “California Act”).  The California Act requires certain companies to make specific disclosures regarding their efforts to eliminate slavery and human trafficking from their supply chains.

Organizational Structure and Supply Chain

Ball Metalpack, LLC (“Ball Metalpack”) supplies innovative, sustainable packaging solutions for food and household products throughout the United States.  Ball Metalpack’s principal products include metal food and household products packaging.

Ball Metalpack has a varied and diverse supply base, with Ball Metalpack sourcing supplies world-wide through various supply chains such as raw materials for our products; distribution; procurement of equipment; sales, marketing and information technology goods and services; as well as other goods and services integral to our business.  We expect that our business partners will uphold our values, including complying with our Supplier Guiding Principles, which prohibits forced labor, slavery and human trafficking within their operations and their own supply chains.   The Supplier Guiding Principles are discussed further below.

Human Rights Policies

Ball Metalpack established policies to support our commitment to treat people with dignity and respect, and that specifically address protecting human rights by prohibiting slavery and human trafficking.  These policies address, among other things, noncompliance by employees and vendors working with and for us.

Ball Metalpack’s Human Rights Policy sets forth our commitment to respect and protect human rights in the workplace and to our responsibility to respect and safeguard human rights.  Ball Metalpack endorses the principles set out in the Universal Declaration of Human Rights and the International Labour Organization based on respect for the dignity of the individual without distinction of any kind.  Our policy outlines Ball Metalpack’s commitment to protecting the human rights of our employees; to avoid indirect involvement in human rights abuses through our supply chain; and to respect human rights in the local communities in which we operate. The Human Rights Policy specifically prohibits child, forced or compulsory labor, servitude, slavery and human trafficking.

Ball Metalpack’s Child and Forced Labor Policy is to stringently adhere to all regulations and laws related to child labor laws and forced or compulsory labor.  Ball Metalpack will not employ individuals under the age of 18 in a manufacturing environment, or in any setting deemed hazardous by the U.S. Fair Labor Standards Act, or other national equivalent.  Persons under the age of 16 will not be employed in any capacity.

Ball Metalpack’s Corporate Compliance Policy sets forth Ball Metalpack’s policy to comply with all laws, which would include laws related to slavery and human trafficking.  The Corporate Compliance Policy provides for a hotline whereby employees may report possible violations anonymously, either by calling the specified numbers or by reports that may be made online.  Hotline information is displayed on posters in our facilities and information is also available to employees online on our company portal.

Ball Metalpack’s Business Ethics Code of Conduct (the “Code of Conduct”) sets forth our expectations of the ethical business conduct of our employees.  The Code of Conduct reinforces the fundamental message that Ball Metalpack is committed to conducting all of our affairs using the highest ethical standards, and in compliance with all laws, rules, regulations, policies and procedures applicable to Ball Metalpack’s operations worldwide, and specifically sets out our zero tolerance policy regarding child and forced labor and human trafficking in our own business, as well as in our supply chain.

Due Diligence and Verification

Ball’s Metalpack’s Supplier Guiding Principles, included in our standard supply agreements, requires our suppliers to comply with all applicable laws, rules, regulations. The expectation of equitable and safe working environments, and adherence to best practices related to legal working age and unlawful abuse; no forced labor, slavery, servitude or human trafficking; and no discrimination in the work place is also set forth.   Ball Metalpack is able to verify, evaluate and address issues, as suppliers are expected to demonstrate compliance with the Supplier Guiding Principles at Ball Metalpack’s request.  If Ball Metalpack becomes aware that a supplier is not in compliance with our Supplier Guiding Principles, the action or inaction of the supplier is reviewed by the company, and may lead to corrective measures, including reconsideration of our commercial relationship with the relevant supplier.

Certification

We ask our direct suppliers to certify that the materials in their products comply with the laws and regulations of the countries where they are sold, including those related to the prohibition of forced labor and human trafficking.  This certification is included as an exhibit to our supply agreements and is re-certified when contracts are renewed.

Audits

We do not have a self- or third-party plan for auditing our suppliers to evaluate their compliance with sustainability and social responsibility goals, including those related to human trafficking and slavery.

Identification of Risk and Training

Identification of risk related to human rights violations necessarily depends largely on our employees who have the direct relationships where these practices are likely to occur.  Ball Metalpack conducts bi-annual training as part of its overall compliance program, which includes training on our Code of Conduct and other policies.  Historically, a selected group of employees has been required to complete the training.  We are expanding the population of employees that will be trained going forward, and the long-term goal is for all of Ball Metalpack employees to certify that they understand and comply with our Code of Conduct, among other Ball Metalpack policies.  We are also preparing training sessions for key employees, which may include a specific module on human trafficking and modern slavery.

We will continue to monitor compliance with our policies through the use of the compliance hotline, investigate any possible violations, and continue with our awareness activities.