47 Business Ethics Our culture is rooted in a strong foundation of integrity and sound governance, and our Twenty by 30 program reflects this commitment. We know that operating successfully can only be done when we have the trust of our stakeholders. This includes our associates, customers, suppliers, shareholders, partners, the governmental and non-governmental organizations we work with and the communities where we live and conduct business. We earn that trust by doing what is right and ethical. We comply with applicable legal, regulatory and industry code requirements and uphold the highest principles of integrity and standards in every aspect of our business and every market in which we operate. That mindset is ingrained into our business culture and is monitored, enforced and improved through our globally deployed Code of Business Conduct and Ethics. Available in nearly 20 languages, the Code outlines the high level of ethical behavior expected from our directors, officers and employees. Our Code of Business Conduct and Ethics is supplemented with standalone policies for certain issues covered by the Code, such as Antitrust Law Compliance, Anti-Corruption Law Compliance, Trade Sanctions Law Compliance, Related Party Transactions and Environment, Health and Safety Compliance. Acting with integrity extends to our suppliers. We direct supplier compliance through our Supplier Code of Conduct which is informed by the Crown Code and other important public principles, such as the United Nations Global Compact. It 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. We expect each supplier to comply with the code’s principles, or comparable provisions of its own code of conduct, in all its dealings with us. ETHICS MANAGEMENT Our Code of Business Conduct and Ethics is reviewed regularly by our Board of Directors, management and outside counsel to consider evolving issues and best practices. Final decisions on changes to the Code must be approved by the Board of Directors. In addition, each year, qualified management personnel are required to participate in Crown’s Code of Business Conduct and Ethics training, which includes certification of the employee’s compliance with the Company’s standards of business conduct and disclosure of any known potential violations of such standards. Our proactive compliance training program includes live and online Code training in numerous contexts for employees of all levels. Approximately 8,200 employees, or over 31% of our workforce, including all our senior executives and middle management, received online Code training in 2021. In furtherance of our commitment to operating in accordance with the highest ethical standards, we offer several ways for employees and other stakeholders to report concerns about suspected unethical behavior safely, promptly and confidentially: ⹅ Speak directly to their supervisor or plant manager (or equivalent). ⹅ Contact their HR Manager, the Legal Department or their Regional Compliance Officer for the relevant policy. ⹅ Call Crown’s Business Ethics Line using the 24/7 toll-free reporting hotline (877-222-3029). We handle all inquiries promptly and investigate to the fullest extent necessary. Violations of the Code of Business Conduct and Ethics by employees are subject to disciplinary action up to and including termination of employment. Any employee who reports a violation will be treated with dignity and respect and will not be subjected to any form of discipline or retaliation for reports made in good faith. Senior management regularly reports to the Audit Committee of the Board of Directors on the status of open Code matters. ANTI-CORRUPTION POLICIES No Crown employee, officer, director or independent third party acting on behalf of the Company 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 the Company, to cause the party to act contrary to their duties or, in the case of a government official, to influence that FAST-TRACKING PROGRESS FOCUSING ON OUR CORE OUR PEOPLE & COMMUNITIES REPORT OVERVIEW REPORTING STANDARDS SUSTAINABILITY STRATEGY FROM OUR CEO WHO WE ARE
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