Supplier Code of Conduct

Crown Holdings, Inc., through its worldwide family of companies (“Crown”), is committed to acting ethically and responsibly in all facets of our operations. Crown’s Code of Business Conduct and Ethics (the “Crown Code”)¹ which applies to Crown’s directors, officers and employees and is available on its website, governs its own conduct. In that document, Crown commits to follow the words, as well as the spirit, of the law in the countries where it operates and requires all its employees to strive to adhere to the highest standards of ethics, morality, honesty and decency in the performance of their duties. 

This Supplier Code of Conduct (the “Supplier Code”), which is informed by the Crown Code and other important public principles such as the United Nations Global Compact, is designed to align the ethical objectives and conduct of all of Crown’s suppliers, all over the world, with the standards that Crown applies to its own personnel. All Suppliers shall comply with the principles described below, or comparable provisions of their own codes of conduct or operating standards, in all of their dealings with Crown. 

In addition, Core Suppliers shall proactively monitor their suppliers and conduct appropriate due diligence processes aiming to ensure compliance across their respective supply chains with the principles set forth below. Crown defines a Core Supplier as one that sells raw materials, components, or finished goods that Crown determines are fundamental and critical to our ability to produce and sell our products globally.  Raw materials suppliers will be defined as core if they meet a series of targets of regional importance.

Sustainability is a basic value at Crown. One key objective of this Supplier Code is to advise our suppliers of, and align our suppliers with, our sustainability values.  We encourage our suppliers to continuously work to implement sustainable development principles like the ones in this Supplier Code in their own operations and in their supply chain.

To Whom Does This Supplier Code Apply?

A Crown supplier is any third party with whom Crown has an active commercial relationship for the supply of goods or services, which includes suppliers of raw materials and machinery, suppliers of other goods and services, contractors, consultants, brokers and agents. 

Crown reserves the right to add to or modify this Supplier Code from time to time. Suppliers are expected to comply with the latest version of this Supplier Code that is posted on Crown’s website at www.crowncork.com/investors/policies/supplier-code-conduct or otherwise provided directly to them. 

The Principles of the Supplier Code

All suppliers must adhere to the following principles: 

1. Compliance with Law

Suppliers must comply with the words and spirit of all applicable laws, rules, regulations and orders of all government bodies in the performance of their business. 

2. Human Rights/Employment Practices/Health & Safety

Crown requires that its suppliers support and respect the protection of human rights. This Supplier Code is designed to ensure that Crown suppliers are not complicit in human rights abuses and requires compliance with all principles under Crown’s Human Rights Policy [www.crowncork.com/investors/policies/human-rights-policy]. Crown expects its suppliers to follow universally-accepted employment practices and to prioritize health and safety. Crown requires the following:

• Suppliers shall not employ anyone under the legal working age.
• Suppliers shall not permit the use of forced or compulsory labor, slavery or human trafficking in their own facilities or in their supply chain.
• Suppliers shall respect the rights of indigenous people as defined by applicable law and international human rights standards.
• Suppliers shall provide a workplace free from harassment, including sexual, verbal, physical or demonstrative behavior that creates an offensive, hostile or intimidating environment in violation of applicable law.
• Suppliers shall not discriminate against current or prospective employees on grounds of race, ethnicity, color, national origin, ancestry, nationality, citizenship, religion, age, gender (including gender identity or expression), sexual orientation, disability, genetic information, uniformed service, veteran's status or any other characteristic protected by applicable law, ordinance or regulation.
• Suppliers shall endeavor to provide a safe work environment in compliance with all applicable laws or, in the absence of applicable laws, best industry practices. Suppliers shall take actions to minimize accidents, injury and illness during the course of work.
• Suppliers shall recognize the rights of freedom of association and collective bargaining under applicable law.
• Suppliers shall comply with all applicable labor laws, including those related to wages, overtime, vacations, absences, disability, maximum working hours and legal right to work. 
• Suppliers shall ensure that their employees have continued access to safe water, sanitation and hygiene on work premises; any supplier providing housing to employees shall ensure it is safe, clean, and compliant with local laws.
• No supplier employee, contractor, or job applicant may be required to pay recruitment fees or any costs related to the hiring process, whether charged by the supplier itself or by any third party acting on its behalf. Workers must retain full freedom of movement and may leave the workplace in accordance with the supplier’s reasonable policies and applicable laws.
• Except where expressly required by local law, workers must not be asked to surrender personal documents—including passports, identity papers, bank cards, or work permits—as a condition for hiring or continued employment.
• Suppliers shall establish clear and documented procedures regarding employee discipline that adhere to local laws. The use or threat of physical punishment or abuse is prohibited.

3. Environment

At Crown, environmental commitment is a fundamental part of our business philosophy. Crown recognizes that the protection of human health and the environment is a sound business practice that conserves resources and safeguards employees, customers, the general public and the environment. Suppliers are expected to align their practices, where applicable, with Crown’s current sustainability program, available at www.crowncork.com/sustainability.

Responsible enterprises consider the potential environmental impacts of daily business decision-making processes, opportunities for conservation of natural resources, source reduction, material recycling, and pollution control to improve air and water quality and reduce landfill wastes.  Crown requires its suppliers to conduct business in accordance with all applicable environmental laws and highly recommends that its suppliers adopt sustainable practices in the conduct of their operations so as to conserve natural resources and minimize their environmental impact. 

4. Business Integrity and Anticorruption

In support of Crown’s values of ethics, morality, honesty and decency in its work, Crown requires the following of its suppliers:

• Antitrust/Competition Law Compliance – Suppliers will fully comply with the antitrust and competition laws of the countries in which they do business. For example, suppliers will not engage in collusive bidding, price fixing, price discrimination or any other unfair trade practices in violation of applicable antitrust and competition laws.
• Anti-Bribery/Anti-Corruption – No Crown employee or third party acting on behalf of Crown may pay, offer or promise to pay, or authorize payment to any party, public or private, in any country, in order to secure an improper benefit for Crown. Nor may they accept or solicit such payment. Suppliers shall not engage in any improper payments, offers or solicitations to Crown personnel. Reasonable, noncash gifts having a token or nominal (modest) value, as well as reasonable meals and entertainment for legitimate business purposes, are acceptable provided they are not intended and cannot be construed as bribes, kickbacks or other forms of compensation to the Crown recipient.  The giving to any Crown personnel of any cash gift (including cash equivalents such as gift cards, stocks or bonds) or any personal loan is strictly prohibited regardless of value.
• Conflicts of Interest – Crown’s personnel are expected to act always in the best interest of Crown and to avoid personal, business or other conflicts of interest. Crown expects its suppliers to support this requirement by immediately reporting to Crown any actual or potential conflict of interest that may arise in our relationship.
• Confidentiality – Suppliers who receive information from or on behalf of Crown on a confidential basis shall maintain that confidentiality and shall use the information only in the performance of their obligations to Crown, unless specifically agreed to in writing otherwise by Crown.
• Intellectual Property Protection – Suppliers shall respect the intellectual property rights of Crown and others and comply with their legal and contractual obligations to Crown with respect to the protection of all intellectual property provided to them by or on behalf of Crown. 
• International Trade – Suppliers shall assist Crown by complying with all trade laws applicable to Crown in the performance of their obligations. Those trade laws include US Anti-Boycott Laws as well as US and EU trade sanctions laws, export controls laws, import laws and laws regarding supply chain security.
• Data Protection and Privacy – Suppliers shall respect privacy rights and comply with all applicable laws relating to cybersecurity, data protection and data security. Suppliers shall handle all data entrusted to them by Crown with at least the same level of care that a reasonable owner would use, which includes maintaining the confidentiality, integrity, and availability of such data. Suppliers shall retain Crown data only for as long as necessary to fulfill contractual obligations or comply with applicable legal requirements.  Upon Crown's request, completion of services, or termination of the business relationship, suppliers shall securely return or permanently destroy Crown data and, upon request, certify such destruction.
• IT Security Controls and Risk Management – The following provisions apply to suppliers with data on behalf of Crown. Such suppliers are expected to implement appropriate technical and organizational security controls, including supply chain security as well as multi-factor authentication, taking into account relevant international standards. They also must conduct regular risk assessments and implement measures to mitigate identified risks to the security of  data provided by Crown and Crown’s IT systems (notably by updating and patching their software and systems and device configuration) including vulnerability handling and disclosure. To that effect, such suppliers must have effective incident response plans in place to promptly detect, respond to, remediate, analyze and recover from cybersecurity incidents or data breaches. Suppliers shall notify Crown promptly and without undue delay upon becoming aware of any actual or suspected cybersecurity incident, data breach, ransomware event, unauthorized access, or compromise that may affect Crown data, Crown systems, or services provided to Crown. Suppliers shall provide all relevant information on the incident or data breach and fully cooperate with any investigation or remediation efforts by Crown or by legal authorities. 
• Business Continuity and Disaster Recovery – Core Suppliers must have business continuity and disaster recovery plans that include a documented strategy (notably in case of cyber-attack, Voice or Data (IT) communications outage, natural disaster, weather, fire, utility / infrastructure outages, equipment failure) that outlines how they will (i) continue to operate and deliver products or services during and after environmental or operational incidents, and (ii) ensure the continued availability and integrity of data provided by Crown and Crown’s systems in the event of a cybersecurity incident, data breach or other disruption (including back-up and crisis management).  Upon request, Core Suppliers should be able to provide the details of such plans. Core Suppliers shall periodically test business continuity, disaster recovery, and cyber resilience plans and maintain documented procedures to detect, withstand, respond to, recover from, and learn from operational disruptions and cybersecurity incidents.
• Artificial Intelligence – Crown expects its suppliers to use artificial intelligence systems, including generative AI, (“AI”) responsibly and in a manner consistent with this Supplier Code and applicable law. Suppliers shall not use or expose any Crown confidential information, personal data, materials, Crown data, or Crown intellectual property, including data derived from goods or services provided to Crown, in connection with any AI for training, model improvement, or any secondary or non-essential purpose, without Crown’s prior authorization. Suppliers shall implement appropriate safeguards when using AI in connection with goods or services provided to Crown, including measures designed to protect confidentiality, personal data, and the integrity and reliability of outputs, including, where appropriate, human review. Suppliers shall disclose to Crown any use of AI in the provision of goods or services where such use could reasonably affect the nature of the services, the handling of Crown data, or the outputs delivered to Crown. Suppliers shall conduct reasonable diligence on any third-party AI tools or services used in connection with goods or services provided to Crown and shall remain fully responsible and liable for their use of AI, including the acts and omissions of any third-party providers or subcontractors. Suppliers shall not use AI in a manner that violates applicable law, infringes intellectual property rights, or results in misleading or unreliable outputs in materials provided to Crown.
• Origin Mapping – Suppliers must be capable of disclosing potential sources of primary origin associated with the products or services provided to Crown.  If requested by Crown, suppliers will provide supply chain mapping back to the origin. This obligation applies to, for example, conflict minerals covered by applicable U.S. law and origin information required for Crown’s compliance with applicable tariff laws. Crown expects suppliers to advise Crown if their products contain conflict minerals as defined in U.S. or other applicable laws.
• Financial Controls – Suppliers shall maintain strong financial controls and keep complete and accurate records of all business operations and transactions involving Crown in accordance with applicable retention policies and laws. Participation in money laundering or the financing of terrorists or criminal activities in any way is strictly prohibited.
• Tax Evasion – Crown expects its suppliers to have and maintain policies and procedures designed to prevent the facilitation of tax evasion by another person (including employees of supplier, and any authorized sub-contractors and any associated persons). Suppliers shall not engage in any activity, practice or conduct which would constitute an offense under any applicable local law or regulation.

Crown expects its suppliers to foster an environment where concerns relating to possible unethical or illegal behavior can be raised and are addressed without fear of retaliation. To that effect, Crown expects its suppliers to establish appropriate grievance mechanisms where (i) their employees, directors, officers, consultants, customers, vendors, sub-contractors and business associates are able to raise concerns regarding possible violations of any applicable legal requirement or policy (notably applicable codes of ethics and human rights policies), (ii) suppliers respond to such concerns appropriately, including through investigations and other appropriate methods, in a neutral and objective manner in compliance with applicable local laws and regulations, and (iii) corrective actions are taken if warranted.

Continuous Improvement

Striving for excellence and continuous improvement is an important facet of how Crown conducts business. Crown encourages and recommends suppliers to:

• Strive to track and reduce their environmental footprint, commit to continuous improvement on sustainability issues, and support the achievement of the goals of Crown’s sustainability program. 
• Continuously improve their products and/or services so as to improve quality, reduce cost and reduce the impact of their products on the environment. 
• Maintain accurate supply chain records.
• Identify, set targets and implement action plans for reducing environmental impacts in the areas of water, wastewater, energy, greenhouse gas emissions, waste, landfill use and packaging. In that context, if requested by Crown, raw material suppliers commit to deliver to Crown a Greenhouse Gas reduction transition plan showing on a yearly basis their strategy to limit global warming aligned with applicable legal obligations.
• Source raw materials from sustainable sources in line with applicable laws (for instance, the EU Deforestation Regulation).
• Strive to improve their health and safety performance notably by reducing the number of accidents, injuries and illnesses during the course of work.

Accountability and Compliance

Crown expects its suppliers to implement appropriate policies, management systems, procedures and staffing to meet the expectations of this Supplier Code. Crown also expects its suppliers to effectively communicate to their personnel the standards to which the supplier is committed, as well as relevant laws and regulations.

Crown reserves the right to validate supplier’s compliance with this Supplier Code (or the equivalent provision of a supplier’s code of conduct) through certifications of compliance or audits conducted by Crown personnel or third-party assurance providers which may include reviews of supplier’s supporting documentation and records, questionnaires, on-site visits, or any other appropriate evaluative method.  If Crown determines that a supplier is not in compliance with this Supplier Code, Crown may review the non-compliance with the supplier and require the supplier to implement corrective measures to achieve compliance. Entering into a contractual relationship with Crown shall evidence suppliers’ agreement to the principles described in this Supplier Code.

Review and Monitoring

Crown will periodically review this Supplier Code and amend it to respond to changes in legislation and best practices in an effort to improve its effectiveness. 

The review and revision of this Supplier Code includes input from, at a minimum, senior management in the following functional areas within the Company: Procurement, Sustainability, Human Resources, Environment, Health and Safety, Information Security, Legal and Risk Management.

This Supplier Code is available in all prevailing languages where Crown facilities are located.*

* Translations are in process and will be available soon.

1. Signode Industrial Group LLC, which is Crown’s Transit Packaging Division, has a parallel policy (Statement of Principles of Conduct) which aligns with Crown’s Code of Business Conduct and Ethics.↩