Modern Slavery and Human Trafficking Statement for Financial Year Ending December 31, 2017

INTRODUCTION

Sealed  Air  Corporation’s  vision  is  to  create  a  better  way  for  life.  It  is  a  vision  rooted  in  sustainability and ethical business practices. It inspires us to continuously strive to develop purposeful innovations that not only fulfil our customers’ needs but also protect products being shipped, and improve the security and safety of the food we eat.

Since the Company’s publication of its first Modern Slavery Statement in June 2017, in the past year we have continued our commitment to understanding risk, and ensuring we have in place the most effective responses to that risk as the very nature of our business requires a global culture of responsibility and we are committed to acting ethically and with integrity and transparency in all business dealings; and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply  chain.  This  statement  sets  forth  our  continued  commitment  to  combat  unethical  practices in supply chains, as well as comply with requirements of the UK Modern Slavery Act 2015 and the California Transparency in Supply Chains Act (“the Acts”).

OUR BUSINESS, STRUCTURE AND SUPPLY CHAIN

We are a global leader in food safety and security, and product protection. We serve an array of markets including food and beverage processing, food service, retail, and commercial and consumer applications through our portfolio of widely recognized brands, including Cryovac® brand food packaging solutions, Bubble Wrap® brand cushioning, Jiffy® protective mailers, Instapak® foam‐in‐place systems and I‐Pack® and e‐Cube™ automated packaging systems. In 2017,  the  Company  generated  revenue  of  approximately  $4.5  billion  by  helping  our  customers achieve their sustainability goals in the face of today’s biggest social and environmental challenges. In the same year, the divestiture of one of the Company’s brands ‘Diversey Care’ marked a significant milestone and transformation of the Company.

We have approximately 15,000 employees globally and operate through our subsidiaries and have a presence in the United States and 58 other countries, enabling us to distribute our products to our customers in 122 countries.

Our  supply  chains  include  the  sourcing  of  raw  materials,  packaging  components,  contract  manufactured goods, equipment and other direct materials, such as inks, films and paper principally related to the provision and manufacturing of goods. Our principal raw materials are  polyolefin  and  other  petrochemical‐based  resins,  as  well  as  paper  and  wood  pulp  products.

OUR POLICIES

We have put in place a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

  1. Global Anti-Slavery and Human Trafficking Policy. This policy sets forth our stance on modern slavery and how employees can identify any instances of these practices and where they can report potential non‐compliance.
  2. Code of Conduct. This provides the foundational standards of conduct for all aspects of our business, and is applicable to all our employees and operations globally. It includes provisions related to, among other things, ethical standards, compliance with laws, safe working conditions, and whistleblowing which encourages employees to raise concerns about issues they are observing or experiencing in the workplace or within our business functions without fear of reprisal.
  3. Supplier Code of Conduct.  This code explains our commitment to ethical workplace practices and sets forth the ethical and legal standards we expect suppliers will adhere to and is aligned to the Company’s Code of Conduct. Suppliers are required to demonstrate that they provide safe working conditions, treat workers with dignity and respect, and act in accordance with all laws and international and organizational standards governing slavery or forced labor (e.g., International Labour Organization). Additionally, supplier violations of this code may lead to the termination of the business relationship.

DUE DILIGENCE & VERIFICATION OF SUPPLY CHAIN RISK

We expect all suppliers within our supply chain to comply with our values and standards set out in our company Code of Conduct and Supplier Code of Conduct. As part of our evaluation process, we may conduct due diligence when considering engaging new suppliers, and regularly review our existing suppliers by:

  • Performing internal supplier audits or assessments through our own staff or a third-party, which may have a greater degree of focus on slavery and human trafficking where these types of risks are identified; and
  • Demanding corrective measures In the event the company becomes aware of any actions or conditions not in compliance with our Supplier Code of Conduct. We also may terminate an agreement with any supplier who does not comply with our Supplier Code of Conduct or the contractual provisions governing compliance with laws and the provisions set forth in our Code of Conduct.

TRAINING

Our company has a robust global compliance training program in place comprised of mandatory training for employees related to code of conduct and ethical business practices using our E-Learning tool. We’re committed to offering training to employees globally that is specifically related to awareness of modern slavery and trafficking in business.

PERFORMANCE INDICATORS & AUDITS

We are taking the following steps to measure and maintain internal accountability standards and  procedures  for  suppliers  who  fail  to  meet  company  standards  regarding  slavery  and  trafficking and to ensure that slavery and human trafficking are not taking place within our business or supply chain:

  • Our Supplier Code of Conduct was issued to suppliers.
  • We  may  verify  our  suppliers’  compliance  with  our  Supplier  Code  of  Conduct  by conducting unannounced supplier audits or internal assessments.
  • We require Suppliers agree to comply with all laws, our Code of Conduct and Supplier Code of Conduct, as applicable, by way of contractual provisions in our supplier agreements and purchase orders.

APPROVAL OF THIS STATEMENT

This  statement  is  made  pursuant  to  the  relevant  legal  requirements  of  the  United  States (including the individual states therein) and the United Kingdom.

Emile Chammas
Senior Vice President & Chief Supply Chain Officer