Greif, a global manufacturer of industrial packaging

Why Ethics & Compliance Matters

102-11

Precautionary Principle or approach

102-16

Values, principles, standards, and norms of behavior

103-1

Explanation of the material topic and its Boundary

103-2

Explain management approach components

102-3

Location of headquarters

205-1

Operations assessed for risks related to corruption

205-2

Communication and training about anti-corruption policies and procedures

412-2

Employee training on human rights policies or procedures

GRI 102-11; 102-16; 205: 103-1, 103-2,103-3; 205-1; 205-2; 206: 103-1, 103-2, 103-3; 412-2

The principles set forth in The Greif Way establish a company culture rooted in ethics and compliance. We believe that behavior influences culture and culture determines performance, which is why establishing positive behaviors is important to our business. Every day, our colleagues implement these principles, which are formalized through the policies that govern our organization.

Governance

Greif maintains a broad set of policies that promote ethical behavior and support us in meeting our compliance obligations:

Each policy is managed, reviewed and implemented by a diverse team comprised of representatives from human resources, finance and legal. We regularly review our policies and revise them as necessary to strengthen language, address emerging risks and communicate best practices. Greif leverages training and audits to actively implement our policies. We require each of Greif’s over 2,800 manager-level and above colleagues to complete policy training. We actively encourage our colleagues to anonymously report ethics and compliance violations through our Ethics Hotline. The Hotline is administered by a third-party provider to protect the anonymity of our colleagues and is available 24 hours a day, seven days a week. Information on the Hotline, and related policies, is included in the Code of Conduct – which all colleagues receive training on through our internal colleague portal and via posters at each facility. Complaints can also now be reported via an online portal or e-mail as well as by phone globally. All reported incidents are sent to our newly formed Ethics Committee, chaired by Greif’s General Counsel, for review. Incidents are reported to the Audit Committee of Greif’s Board of Directors quarterly. In 2020, we investigated and resolved 97 percent of the complaints from our Ethics Hotline.

To validate our compliance to our established policies, we conduct annual Sarbanes-Oxley Act (SOX) audits for all our facilities that are material to our financial statements. Each year we ensure that facilities accounting for at least 75 percent of our revenue are included in our Sarbanes-Oxley scope. In total, Greif has 281 auditable entities. In addition to required SOX audits, Greif conducts risk-based audits at each of our facilities at least once every five years. Facilities that are audited are identified through a multi- layered process that includes management surveys, discussions, approval by executive leadership and reports to the Ethics Hotline. Following this process, in 2020 we completed 21 risk-based audits. We continue to strengthen our internal control environment as we leverage shared processes across locations.

In 2020, we published an updated Code of Conduct communicating our commitment to The Greif Way and defining globally applicable standards of conduct. The updated Code of Conduct presents this information in a more easily understood and digestible format, which more clearly reinforces the key behaviors we desire our colleagues to demonstrate. We accompanied the updated Code of Conduct with a new online training course that will also be included in Greif University. During 2020, we also developed an updated Supplier Code of Conduct for publication in early 2021. The updated Supplier Code of Conduct will better outline our business ethics expectations.

Throughout the COVID-19 pandemic our global and regional task forces met at least weekly to develop protocols, communications and monitoring to maintain the health and safety of our colleagues and compliance with national and local regulations. Through collaboration with outside counsel, our Human Resources, Health and Safety and other Greif teams were able to stay abreast of changing regulations and develop a set of protocols that are consistent across all our plants.

21

SOX Audits Completed

We work to ensure our internal policies are implemented and our operations are compliant with relevant regulations.

Goals & Progress

In 2017, we established our first ethics and compliance goals. By the end of fiscal year 2025 we will:

Provide online training of the Greif Code of Business Conduct and Ethics to 100 percent of colleagues with access to computers
Provide training and information on the Greif Anti-bribery Policy to 100 percent of colleagues for whom training is relevant
Provide online training of the Fair Treatment of Others Policy to 100 percent of colleagues with access to computers, and provide accessible and traceable information to all colleagues

In 2020, 91.1 percent of colleagues with access to computers completed training on Greif’s Code of Business Conduct and Ethics. As we transition our training program to Greif University, we will leverage this platform to further promote and distribute training to our colleagues. Greif University will allow us to more readily push training to the relevant colleagues. In 2020, 83 percent of eligible colleagues completed anti-bribery training. In addition, 74 percent of colleagues for whom training is relevant received training on our Insider Training Policy.