We are committed to operating in an ethical and honest way and complying with all applicable laws and regulations in all dealings within our business, with others (including customers, suppliers and public officials), and with the communities in which we operate.

Code of Conduct

We are committed to always doing business the right way. We operate with the highest standards of integrity and honesty and comply with all applicable laws and regulations in all dealings within our business, with others (including customers, suppliers and public authorities), and with the communities in which we operate. Our Code of Conduct sets out our commitments, and our expectations for employees and business partners on how to do business the right way.

Preventing bribery and corruption

We do not tolerate any forms of bribery or corruption and we comply with all applicable anti-bribery and corruption laws. We have set out our position clearly within our Code of Conduct and we have also implemented various policies and guidelines including our Anti-Bribery and Corruption Policy. Ardagh Metal Packaging is a signatory of the United Nations Global Compact (UNGC) and is committed to working in alignment with the UNGC’s principles, including that it is against corruption in all its forms.

How we manage compliance

Our Code of Conduct sets out the commitment to acting with integrity and is supported by a compliance framework to ensure that we appropriately manage compliance within our business. Our Chair and CEO set a clear tone from the top to ensure colleagues are clear about the importance of acting with integrity and adhering to our Code of Conduct.

The Board has entrusted the Audit Committee with the oversight of the compliance function and of our risk management. On the compliance side, the Audit Committee has established a Compliance Committee which drives the implementation of our Code of Conduct and ensures that appropriate policies are in place to address Ardagh Metal Packaging’s compliance risks. The Compliance Committee is also responsible for reviewing compliance violations and reporting these to the Audit Committee. The Compliance Committee includes representatives from across Ardagh Metal Packaging’s operating businesses.

In addition to robust governance structures, strong leadership and a clear direction from leadership, compliance issues are reviewed as part of our overall risk management system. Through this we identify and assess our compliance risks, implementing mitigation measures where necessary. We provide employees with training on our Code of Conduct and various key risk areas, including anti-bribery and corruption and competition compliance.

Ardagh Glass Packaging’s enterprise risk management framework includes systems and processes for identifying, monitoring and mitigating business, operational and legal risks. Guided by our risk framework, the business assesses risks in a top-down and bottom-up approach and monitor, controlling and mitigating risks as required.

Coverage of plants with certified management systems 2021-2023

As a business, Ardagh Group is exposed by various risks that could materially adversely affect our operations and can be categorised as risks relating to:

• Business, products and industry
• Supply chain
• Economic, market and political conditions
• Employees and operations
• Information technology systems
• Legal and regulatory matters.

Our Enterprise Risk Management (ERM) Committee regularly reports to the Audit Committee who oversees risk management. In addition, management, including our Chief Risk Officer, informs and updates the Audit Committee and the Board of any material incidents, as necessary.

The objective of issuing Green Financing Instruments is to assist in financing AG’s initiatives to lower our own carbon footprint as well as increase our investment in sustainable projects to transition to a low carbon and circular economy. The issuance of these Green Financing Instruments will also enable AMP to engage with those investors who are committed to allocating capital in support of these objectives.

Sustainable supply chain 2023

To ensure we act ethically across our organisation, we are committed to complying with all applicable laws and to following the highest principles of integrity and standards across our business functions and the markets in which we operate. This commitment is a core part of our business culture and the framework for how we achieve this is set out in our Code of Conduct (Code). The Code applies to all of our employees, officers, directors and third parties working on our behalf. We supplement this Code with standalone policies and statements for certain issues, such as our conflict minerals policy, a tax strategy statement and modern slavery and human trafficking statement.

We set expectations of our suppliers within our Responsible Procurement Policy and monitor progress. This policy is informed by both our own Code as well as important public principles like the Ethical Trading Initiative Base Code, which is founded on the conventions of the International Labour Organisation and is an internationally recognised code of good labour practice, and the United Nations Global Compact (UNGC). This aims to align the objectives and conduct of all our global suppliers with the standards we enforce with our own teams. We expect each supplier to comply with these guidelines, or their own equivalents, throughout their interactions with our organisation.