CAN-PACK GROUP CODE OF ETHICS

The idea behind this Code of Ethics Strongly committed to the principles of corporate social responsibility, the CAN-PACK Group (the “Group”) not only strives to ensure full legal compliance, but also to promote the best market practices for achieving sustainable development while recognising the interests of its many stakeholders.

This document outlines the extent to which the Group obligates its employees and expects its trading partners to comply with best market practices and with the policies contained herein.

It also identifies the rules of conduct for the CAN-PACK Group in areas particularly sensitive to the ethical dimension of business. These are:

I. Our Values II. Business Ethics III. Labour Law and Human Rights IV. Health and Safety V. Environment

The values set out below are the framework of our Code of Ethics, which provides ethical guidance for our trading partners and business associates. We believe that their message is universal and clear, and promotes appropriate standards of conduct in business relationships.

Presented below is a concise summary of our ethical values, designed to help facilitate their application in our day-to-day activities and contribute to our further growth. This Code also identifies legal transgressions, which we refuse to accept.

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adversely operation.

I. OUR VALUES When building its business strategy, the Group is guided by the following values, which its trading partners and business associates are expected to uphold:

affect

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3. Loyalty For us, loyalty is our sense of belonging to the CAN-PACK Group, with its strategy, objectives and corporate structure, and which is manifested in our attitudes and behaviour towards our business associates, subordinates and supervisors, the Group companies as well as our trading partners.

1. Integrity and diligence • We demonstrate uncompromising integrity to everyone inside and outside the Group. • We discharge our responsibilities diligently. • We respect all individuals and their dignity. • We do not tolerate discrimination. • We do not help conceal unethical conduct by others. • We do not tolerate fraud, theft, corruption or misconduct, and we report it when we encounter it. • We do not offer or accept bribes or other unethical tokens of gratitude.

• Any information obtained in the course of our work is the property of the Group and may not be used for our personal benefit, in the same way that the circumstances we find ourselves in as members of the CANPACK Group may not be used for our personal benefit. • We do not conduct or participate in any activities competitive to the Group's business, make use of the Group's proprietary information, unduly add to the costs of the Group's operations or in any way hinder its operations. • We consider disloyalty, understood as a breach of the trust placed by the Group in its trading partners and business associates, as being reprehensible and unacceptable. • We keep confidential any information concerning the Group, its related parties and business associates.

2. Responsibility • Each of us is responsible for the words, actions, decisions and the opinions we express. We feel obliged to deliver on our promises, contractual obligations and any other commitments we make. • We are responsible for our area of service and for our actions or our failure to act within that area. • We are responsible and we look after the Group’s property and resources that are entrusted to us personally or used as part of our work. • We demonstrate our sense of responsibility by avoiding conflicts of interest. • We avoid any direct or indirect subordinate-supervisor relationships with individuals with whom we have personal connections, which could result in a violation of the rules or standards in place at the Group or which could

4. Promoting ethical standards • It is our duty to act and behave ethically. • We communicate the standards of ethical conduct to others, and we have the courage to openly admit when we have ethical doubts. • We expect others to treat us ethically and to comply with this Code of Ethics. 3

UN resolutions. • We prohibit discrimination. • We prohibit forced, slave and unpaid labour. • We prohibit employment of children below the age of 15. • We respect the freedom to form and join employee organisations and trade unions. • We prohibit mobbing, psychological abuse and physical harassment. • We provide fair terms of employment, offering adequate compensation, additional benefits, and paid holidays to our employees. • We require strict compliance with health and safety standards. • We require strict compliance with laws governing competition protection, free trade commerce, unfair commercial practices, and abuse of dominant positions. • We strictly obey import and export laws.

5. Being open and truthful • We talk openly about any transgressions of the law or our adopted standards. • We report any violations of ethical standards. • We do not tolerate attempts to knowingly misstate facts, conceal important information, or mislead others. 6. Building and strengthening positive image of the Group

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• In our dealings with our business partners, we take care to protect the Group's good image and reputation. • We have fair and reasonable rules in place that govern our relationships with our suppliers, customers, trading partners and business associates. • We do not engage in, and we strive to prevent, any business dealings with individuals or entities who follow unethical business practices.

We expect our trading partners to report any instances of violation of this Code, make an effort to investigate their reasons, and remedy their effects.

II. BUSINESS ETHICS 2. Financial or other advantages 1. Legal compliance We prohibit our trading partners and business associates from offering, accepting or receiving any financial or other advantages with a market value in excess of 25 USD in order to influence business decisions.

We are committed to ensuring that our business is run in compliance with the laws of the countries in which we operate, and we expect the same from our employees and trading partners. We may require our trading partners to produce evidence of their legal compliance at any time. Exceeding the minimum requirements of the local laws, the standards outlined herein are the overriding rules of conduct which our trading partners are expected to conform to.

We strictly prohibit offering cash or its equivalents (checks, vouchers, loans, share options etc.) as incentives for obtaining favourable decisions. We prohibit offering any financial or other advantage to public officials holding a government, local government, administrative or other public office.

• We respect human and civil rights, which is our duty arising from the relevant international treaties and

We prohibit our employees and trading partners from participating in any apparently illegal activities, money 4

laundering, bribery, embezzlement or fraud.

based on clear, transparent criteria.

3. Confidentiality

2. Forced labour

We keep confidential, and prevent unauthorised access to, inside information, including but not limited to: pricing, product volumes, discounts, payment arrangements, business plans, marketing programmes and objectives, customer and supplier lists, planned mergers, acquisitions or demergers, changes on the management and executive teams, pending arbitration, court or administrative proceedings, legal opinions and business associate information (personal data, payroll details etc.).

We do not use or accept forced, slave or unpaid labour and human trafficking in our supply chains. Our employees and the employees of our trading partners have, at all times, the right to elect to terminate their employment and retain their identity documents. 3. Mobbing and sexual harassment We do not tolerate any behaviour that is, or has the appearance of, mobbing, psychological or physical abuse or sexual harassment of our employees. Our trading partners are also required to provide a work environment which is free from verbal, physical or psychological abuse in employee interactions, as well as between employees and supervisors.

We require our trading partners to keep confidential any inside information received from CAN-PACK Group companies, and we expect them to ensure their own employees' and contractors' compliance with the confidentiality requirement.

4. Freedom to join organisations We respect, and are committed to upholding, our employees' right to have their interests represented in accordance with applicable laws. We are ready to engage in dialogue with our employees, clarify their doubts and concerns, and work out the best possible solutions to problems together. We expect our trading partners to adopt a similar approach in this respect, and enable formation of employee organisations, including trade unions, and facilitate consultations with employees on matters that concern them.

III. LABOUR LAW AND HUMAN RIGHTS As an employer, we strive to protect the rights and meet the needs of our employees. To that end, we ensure compliance with applicable labour laws, including those governing employment contracts, determination and calculation of working time, fair compensation, and the principles of peaceful coexistence. We expect our trading partners to adopt similar measures in this respect. 1. Discrimination We do not tolerate, in our HR policy or our daily working routines, any form of discrimination on the grounds of race, sex, religion, sexual orientation, organisational membership, age, health or disability, and we respect different cultures and customs. We expect that the policies adopted by our trading partners in the areas of employment, compensation, performance evaluation, and employee promotion to be

5. Working time regulation Employment, timekeeping and working time calculation policies in place at the CANPACK Group are consistent with the law, or with the relevant bargaining agreements and regulations governing individual occupation groups if the latter are more rigorous than the generally applicable laws. We expect our business partners to apply 5

deploy an effective and reliable system of OHS reporting and consultation with our business associates, as well as a local-lawcompliant system for recording accidents, injuries and incidents that may serve to help define further preventive measures. In order to effectively protect people against risks to life and health and to effectively respond to industrial accidents, we have developed and implemented relevant accident and emergency procedures.

international employment standards with respect to their employees. 6. Child labour We do not employ children below the age of 15, and we do not tolerate any such practices by our trading partners.

IV. HEALTH AND SAFETY AT WORK We provide a healthy work environment which conforms to the applicable laws, OHS and fire safety regulations, certification standards and best practices. We consider our OHS procedures to be of critical importance, which clearly define the steps to be taken to protect our employees and third parties involved in the Group's operations. We are consistently eliminating any potential hazards to people or the environment at our sites. We expect our trading partners to adopt similar measures in this respect.

2. Training and personal protection Seeking to ensure a safe work environment, we provide our business associates with appropriate personal protection equipment and relevant training to allow them to safely do their jobs. 3. Substance abuse We consider it unacceptable for any person to possess, distribute or use drugs, alcohol or other illegal substances on CAN-PACK Group premises or on the premises of its trading partners. Any misuse of drugs, medication (contrary to its intended medical purpose), or alcohol outside those premises, which may affect the safe performance of assigned duties, constitutes a violation of safety standards and will not be tolerated.

It is our duty as employees to: • Know the risks related to our job, • Be familiar with occupational safety requirements, and employ adequate collective and personal protection measures in the workplace, • Receive regular OHS training, and enhance our knowledge of potential workplace hazards and related mitigation measures, • Prevent accidents or potentially dangerous occurrences in the workplace, • Follow safety-at-work practices, and report any potentially dangerous occurrences to the supervisor, • Provide assistance to the OHS team in site safety inspections and accident investigations.

V. ENVIRONMENT As a Group, we recognise our responsibility to protect people, the environment and natural resources, and we expect our trading partners to adopt a similar approach in this regard. Our strategy ensures that the Group and its partners conduct business in compliance with applicable laws and environmental regulations and raise the environmental awareness of their employees and external audiences.

1. Accidents, hazards, and OHS systems

1. Environmental management

We are particularly keen to ensure that the Group companies and our trading partners

We take steps to prevent, ameliorate and 6

implement similar procedures in their daily practice.

remove the adverse environmental impacts of our operations. To this end, we employ an environmental management system to monitor our footprint and improve our mitigation measures. We also expect our trading partners to adopt similar environmental protection policies.

6. Pro-environmental activities Having the natural environment at heart, we actively engage in green initiatives, initiating or supporting projects designed to promote pro-environmental attitudes and behaviour among our employees and local communities. We also expect our trading partners to be ready to offer support to similar initiatives.

2. Environmental impact In the course of their business, the Group and its trading partners are required to conform to regulations on noise emissions and air, soil and water pollution. We promote pro-environmental attitudes and actions, such as devising and implementing noise emission and waste reduction programmes. 3. Saving energy and water We implement energy and water saving schemes, and expect our trading partners to do the same. We encourage our staff to put forward energy and water saving ideas, and we also recover and reuse heat. 4. Waste management We monitor and record the type and amount of hazardous and non-hazardous wastes we produce. We think it crucial to have procedures in place for proper waste storage, transport, recycling and neutralisation. The waste we produce is collected by licensed operators and disposed of in accordance with the applicable laws and best available techniques. We also expect our trading partners to adopt similar measures in this respect. 5. Use of chemical substances We have procedures in place for procurement, storage, circulation, and use of chemical substances, which set out the steps to follow when handling and using chemicals, hazardous materials in particular. We also expect our trading partners to 7