Effective January 1, 2012, the California Transparency in Supply Chains Act of 2010 (the “Act”) requires retailers and manufacturers doing business in California to disclose their efforts to eradicate slavery and human trafficking from their direct supply chains. Sonoco Products Company (“Sonoco”, “we”, “us”, “our”) supports the goals of the Act and is committed to protecting and advancing human rights, ethical business conduct, and responsible sourcing throughout our operations and global supply chain. These commitments are reflected in our Code of Conduct, Human Rights Policy, Supplier Code of Conduct, and related compliance programs.
Supplier Due Diligence
1. Verification of Supply Chains
Sonoco’s Legal and Compliance Office monitors current suppliers through the Third-Party Risk Management (TPRM) program, which uses a managed external solution to track risks such as cybersecurity, financial stability, geopolitical factors, compliance, and human rights indicators. Monthly refreshed data covering sanctions, enforcement actions, adverse media, state-owned entity (SOE), and politically exposed persons is used to identify potential modern slavery or other human rights concerns. Any identified issues are escalated to appropriate management; human rights violations are classified as the highest applicable risk category, triggering the most urgent response procedures.
In addition, Sonoco’s human rights risk dashboard evaluates supplier locations using Freedom House ratings to identify those operating in “partially free” or “not free” environments, enabling more frequent Supplier Code of Conduct reviews and supporting transparent communication with customers and stakeholders about human rights conditions in our supply chain. Sonoco does not typically source from regions with elevated trafficking risk.
Verification of supplier compliance is conducted internally by Sonoco. Third-party verifiers are generally not used, but Sonoco reserves the right to do so if Sonoco determines it is warranted based on circumstances.
2. Certification for Direct Suppliers
Sonoco requires our suppliers to uphold our business and ethical standards as outlined in our Supplier Code of Conduct. This Code reinforces our commitment to respecting human rights and clearly defines our expectations for ethical business behavior, responsible labor and safety practices, environmental stewardship, compliance, cybersecurity, and accountability. The Code also includes the right for Sonoco to conduct audits and require proof of compliance with the Code, and to terminate supplier relationships for non-compliance. Generally, Sonoco’s standard U.S. purchase contract forms and general terms and conditions of purchase require suppliers to comply with the Code and with all applicable laws.
3. Audits of Direct Suppliers
Sonoco reserves the right to verify our Supplier’s compliance with our Supplier Code of Conduct. Sonoco monitors supplier compliance using inherent risk questionnaires, control questionnaires, screenings against external data sources, and dashboards.
Audits are typically performed by Sonoco’s Legal and Compliance Office. Sonoco does not routinely conduct independent or unannounced third-party audits but reserves the right to do so if Sonoco determines it is warranted based on circumstances.
In the event that Sonoco becomes aware of any actions or conditions not in compliance with our Supplier Code, we reserve the right to demand corrective measures. Failure to meet Sonoco's requirements would lead to a re-evaluation of the business relationship.
4. Conflict Minerals
Sonoco makes good‑faith efforts to ensure that any conflict minerals (such as tantalum, tin, tungsten, and gold) used in its products are responsibly sourced. Consistent with SEC requirements and OECD Due Diligence Guidance, Sonoco conducts an annual supply chain inquiry to determine whether conflict minerals originate from the Democratic Republic of the Congo and adjoining countries as well as high risk or conflict affected regions. These commitments and processes are detailed in Sonoco’s Conflict Minerals Policy and in our annual Form SD filings with the SEC.
Internal Accountability Standards
1. Employee Recruiting on Onboarding
As part of our internal due diligence practices, Sonoco maintains measures to ensure that no form of modern slavery exists within our workforce. Prior to onboarding, prospective employees are required to provide evidence of their legal right to work. Any staffing agencies engaged by Sonoco undergo appropriate vetting to verify their compliance with ethical and legal standards.
2. Training
Sonoco provides mandatory annual Code of Conduct training for salaried employees. This training includes content related to human rights, modern slavery, and/or ethical business behavior. Employees must pass a knowledge test and acknowledge their responsibility to comply with our policies on Business Conduct.
Employees in supply chain–related roles (such as procurement, sales, and legal) may receive additional guidance as needed on identifying potential human trafficking or forced labor risks, escalating concerns, and applying Sonoco’s supplier standards.
3. Reporting Violations
Sonoco encourages employees, business partners, or affiliated third-parties to report concerns regarding potential violations. Reports may be submitted confidentially and without fear of retaliation through Sonoco’s independently operated whistleblowing hotline. Processes for raising, reviewing, and resolving concerns are reflected in Sonoco’s Employee Code of Conduct and our Supplier Code of Conduct.
Posting Requirement
This disclosure is made in compliance with the California Transparency in Supply Chains Act of 2010 and is intended to be accessible to consumers and the public. Sonoco posts this information on its website through a clear and easily accessible homepage link, as required by law.