Code of Conduct and Anti-Slavery Statement

Code of Conduct

06 June 2022

Petainer Group is committed to an ethical business practice and to make a positive contribution to the
environment and society in general. Our ambition is to closely work with our suppliers to obtain the very
highest standard of these practices.

This Code of Conduct is based on the general principles such as the UN Guiding Principles for Business and
Human Right, UN Global Compact and International Labour Organization Conventions, the Universal
Declaration of Human Rights and the Children’s Rights and Business Principles.

In addition to meeting the requirements of this Code, all shall comply with national laws and regulations as
well as other applicable standards and any other relevant statutory requirements, whichever are more
stringent.

Petainer Group adheres to the principles of this Code and no matter where you work or what you do for the
Company, you have a responsibility to use good judgement and follow this code.

Petainer Code of Conduct applies to all Suppliers, Contractors, Consultants and other providers of services or
goods. It is the responsibility of the Suppliers to ensure that this Code is followed by their Employees, Supply
Chain and other parties acting on their behalf.

Human rights

Petainer Group adheres to all international principles, conventions and declarations of human rights. Equal
rights and opportunities are promoted within the company.

We expect our suppliers to:

  • Have no engagement in or support of discrimination on the basis of race, colour, sex, language, religion, political or other opinion, caste, national/social origin, property, birth, union affiliation, sexual orientation, health status, family responsibilities, age, and disability or other distinguishing characteristics during recruitment and employment.
  • Respect Employees’ right to privacy and integrity.

Working Conditions

Fair working conditions together with a safe work environment are a top priority within the Petainer Group.
This is regardless of position or status within the organization. Systematic health and safety work is a natural
part of our daily activities. Occupational Health and Safety performance is constantly reviewed and improved
to prevent injuries and illness in the workplace, both physical and mental. Internal and external resources are
available to ensure that this is achieved.

We expect our suppliers to:

  • Ensure that all workers have the right to form and join unions or other associations to bargain collectively.
  • Ensure all Employees have a written employment contract.
  • Ensure that Employees receive at least the legal minimum wage, benefits and are compensated for all hours worked. Employees should not be required to work more than 60 hours a week, including overtime, on a regular basis.
  • Ensure that all Employees will be granted paid holiday, parental leave and sick leave if required.
  • Have no engagement in, or take benefit from, any form of child labour.
  • Have no form of forced labour including bonded labour, nor the use of prison, illegal labour or compulsory agreements.
  • Deduction from wages shall be according to law and/or collective agreements and must never be used as a disciplinary measure.
  • Provide an adequate health and safety policy to state intent and guidelines to steer decisions and reach targets.
  • Employees shall be provided with the necessary protective equipment and safety equipment to perform their tasks safely.
  • All equipment shall be maintained, used and provided free of charge where required. The workplace shall be maintained to protect workers from work-related hazards and ensure good working conditions.
  • Incidents and accidents shall be reported and evaluated with the necessary actions being taken as a result.

Business Ethics

Petainer Group is committed to developing a business focused on innovation and sustainable
development. Conducting our business in an ethical and sustainable way is fundamental to our
strategy. Petainer Group has a reputation for integrity in its business activities which is central to our
relationships with Customers, Employees, Suppliers and local communities.

We strive to maintain the highest standards of Ethical Conduct and Corporate Responsibility.

We expect our suppliers to:

  • Have zero tolerance towards bribery and corruption in its worldwide business operations, whether in the public or private sector.
  • Conduct business in an ethical manner.

Environment

Sustainability is a cornerstone of our strategy for the future growth of our business and our long-term vision.
We are committed to the principles of sustainable development and aim to encourage and work with Suppliers
who uphold the same principles as ourselves. To be truly sustainable, our packaging must provide value, be
safe and secure and economically effective. As well as meeting consumer needs, ideally it should be capable
of being reused and recycled.

The foundation of our environmental work is an ambition to protect the environment using renewable
resources in such closed circuits as possible, avoiding the use of environmental pollutants, thereby preventing
contamination.

Petainer Group’s subsidiaries have implemented an Environmental Management System based on an
international standard – ISO 14001.

In the fight against climate change Petainer is committed to strive towards carbon neutrality. We engage in
carbon offsetting projects together with external partners. Offsetting carbon emissions, in addition to
avoidance and reduction, is an important step towards a carbon neutrality.  
We encourage our suppliers to initiate such projects themselves.

Petainer Group strives to minimise the negative environmental impacts of its activities, products and services
through a proactive approach and the responsible management of its environmental impact as follows:
Innovation; develop sustainable products through design and material choice. Products shall be safe, provide
value and be economically effective. Continually explore and assess opportunities to introduce modern
technologies and new equipment which will give cost-effective improvements to activities that have an impact
on our environmental performance.

Carbon Footprint; proactively work to reduce its direct and indirect carbon footprint throughout the whole
supply chain.

Waste-Management; pesticides, chemicals and other hazardous waste are handled in compliance with
applicable laws and regulations. Work proactively to ensure that no hazardous waste ends up in land, air or
water. Implement measures to avoid water pollution by preventing and reducing waste-water. Continuously
strive to reduce waste by reusing and recycling resources.

We expect our suppliers to:

  • Continuously improve the environmental performance of products and services.
  • Maintain effective policies, processes and procedures to manage their environmental impact and to operate their business in a sustainable way.

ANTI-SLAVERY AND HUMAN TRAFFICKING STATEMENT

6 April 2021

Petainer has a zero-tolerance approach to modern slavery both within the Group and within its supply chain.

Petainer is a global business and as such maintains relationships with numerous suppliers in a range of countries. Relationships with the largest suppliers to the Group are managed centrally, whilst other suppliers are managed by procurement teams locally.

The Group has an Anti-Slavery and Human Trafficking Policy which has been issued to all members of the senior management team, as well as those employees who are responsible for the selection and management of suppliers. The policy sets out the Group’s zero-tolerance approach to modern slavery, and the steps to be taken to manage compliance internally and in the supply chain. In addition, the policy sets out responsibilities for setting and enacting the policy, as well as how to report suspected breaches and action to take if they are confirmed.

All key suppliers to the Group are required to complete a “Know Your Supplier” checklist, which includes confirmation of their compliance with certain statements regarding Anti-Slavery and Human Trafficking issues. Petainer does not work with suppliers who do not comply with these statements.

A risk assessment is carried out periodically with regards to the Group’s supplier base to identify suppliers that may be more at risk of non-compliance than others. In cases where a higher risk is identified, further information is requested from the supplier and an audit may be carried out.

Petainer knows of no instances of actual or suspected breaches of Anti-Slavery and Human Trafficking regulations internally or in its supply chain.

Any individual wishing to raise any concern with regards to modern slavery in relation to the Group or its supply chain are encouraged to write in confidence to the Group Financial Controller (either via email to compliance@petainer.com or to the registered office).

We are committed to opposing modern slavery in any form and preventing it wherever we can. We require the same approach from those who work with us and expect it of all those we have business dealings with.

Hugh Ross Group CEO 6 April 2021

Petainer UK Holdings Limited

Capital Tower, 91 Waterloo Rd, London, SE1 8RT

E: enquiries@petainer.com W: www.petainer.com                                                                  Reg.No. 7047255. VAT No. GB241645910