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Disclosure Under the California Transparency in Supply Chains Act of 2010

Effective January 1, 2012, the California Transparency in Supply Chains Act of 2010 requires retailers and manufacturers doing business in California to disclose efforts to eradicate slavery and human trafficking from its direct supply chain.  Sonoco supports the goals of the California Transparency in Supply Chains Act of 2010, and Sonoco enjoys a long history of being committed to the protection and advancement of human rights, and to conducting business in an ethical manner.  Sonoco’s long history of promoting ethical business practices is reflected in our Policies on Business Conduct, which is distributed to each new employee, and re-distributed to all Sonoco employees on a bi-annual basis.  All Sonoco employees are required to acknowledge and adhere to our Policies on Business Conduct, and we routinely offer training on these policies to all employees.

To help implement our commitment to human rights and ethical business practices within our supply chain, Sonoco makes its Policies on Business Conduct available to all our suppliers and requires that all of our suppliers abide by those policies.  We also require our suppliers to abide by Sonoco’s published Supplier Standards, which require all suppliers to adhere to relevant laws relating to fair compensation, working hours, child labor and forced labor, and many other regulations designed to support human rights.  A copy of these Supplier Standards can be found on our website at www.sonoco.com.  Furthermore, our standard supply contracts and terms and conditions of doing business require all of Sonoco’s suppliers to fully comply with all applicable laws, which include laws regarding the prohibition of slavery and human trafficking.  Sonoco reserves the right to verify that its suppliers are in constant compliance with these terms and conditions, and to terminate relationships with any suppliers who do not comply. 

Sonoco predominantly relies on suppliers located in the United States, and we typically do not engage suppliers from countries with an increased risk of human trafficking and slavery.  Sonoco monitors supplier behavior and compliance through our own internal resources, and we typically do not use third-party auditors to monitor supplier behavior.  Sonoco’s purchasing employees are trained to identify and respond to supply chain risks, including issues such as slavery and human trafficking.  For our largest 150 suppliers, we use a detailed scorecard review system to ensure that those suppliers comply with all of Sonoco’s expectations, including compliance with all applicable laws.

Sonoco’s Supplier Standards clearly state that Sonoco expects all of its suppliers to take a proactive role to ensure that they comply with the California Transparency in Supply Chain Act of 2010, and in December 2011, Sonoco sent letters to 1,200 suppliers requesting that those suppliers certify their compliance with the Act.  Sonoco believes that these actions, as well as our overall commitment to human rights and business ethics will help prevent slavery and human trafficking within our supply chain.