Human Rights Policy

Introduction

Human Rights represent the fundamental principles that uphold the dignity and equality of all individuals. Sonoco Products Company (“Sonoco”) is committed to ensuring these rights are respected, protected, and fulfilled for every person within our organization and the communities we serve.

Sonoco adheres to internationally recognized human rights standards, including those outlined in the International Bill of Human Rights and the principles concerning fundamental rights set forth in the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work.

Purpose

The Human Rights Policy (the “Policy”) outlines Sonoco’s approach to human rights, including the standards we uphold, the mechanisms we use to address violations, and the strategies we employ to contribute to the realization of human rights globally. Sonoco strives to integrate human rights considerations into everyday practices, engage with stakeholders constructively, and be accountable for our actions.

Scope

This Policy applies to all Sonoco operations globally, including all divisions, subsidiaries, and affiliated companies. This includes:

  • Employees - defined as all Sonoco employees, directors, and officers; and
  • Third Parties - defined as individuals and entities that are not Sonoco employees but perform work for, represent, or do business with Sonoco, including shareholders, independent contractors, casual and agency staff, paid and unpaid trainees, interns, volunteers, suppliers, and customers.

Employees and Third Parties are collectively referred to in this Policy as “Covered Persons.”

Sonoco’s Human Rights Commitment

Respect for human rights is a basic tenant of Sonoco’s beliefs and is consistent with our values. Our approach to human rights begins with understanding how our activities may positively or negatively impact our employees, communities, and third-party partners.

Sonoco operates in diverse cultures and communities worldwide. Sonoco’s Employee Code of Conduct and Supplier Code of Conduct establish a global framework for responsible operations and reflect the principles set forth in internationally recognized standards, including the International Labour Organization (ILO) Declaration of Fundamental Principles and Rights at Work and the International Bill of Human Rights. We also actively participate in the United Nations Global Compact.

Consistent with these frameworks, Sonoco is committed to promoting and upholding the following principles:

  • Fair and safe work
  • Rights of children and abolition of child labor
  • Prohibiting forced or compulsory labor and human trafficking
  • Non-discrimination
  • Freedom of Association and collective bargaining
  • Indigenous people’s rights

Sonoco supports these principles by developing and implementing appropriate policies, procedures, and practices that align with applicable laws and the specific contexts in which we operate. This Policy is intended to comply with applicable human rights laws and regulations, including, but not limited to, the ILO Declaration of Fundamental Principles and Rights at Work and the International Bill of Human Rights.

Definitions

Harassment – A range of unacceptable behaviors and practices, or threats thereof, whether a single occurrence or repeated, that aim at, result in, or are likely to result in physical, psychological, sexual, or economic harm.

Discrimination – Any distinction, exclusion, or preference made based on characteristics such as race, color, sex, age, physical appearance, religion, political opinion, national extraction, or social origin, which has the effect of nullifying or impairing equality of opportunity or treatment in employment or occupation.

For the purposes of this definition, discrimination covers all aspects of employment and occupation, including access to employment, vocational training, promotion, working conditions, remuneration, and termination. A difference in treatment based on the inherent requirements of a particular job shall not constitute discrimination where it is legitimate, proportionate, and objectively justified.

Discrimination may occur in various forms, including but not limited to:

  • Direct discrimination – treating a person less favorably explicitly because of a protected characteristic.
    Indirect discrimination – applying a seemingly neutral provision, criterion, or practice that puts individuals with a protected characteristic at a particular disadvantage, unless it can be objectively justified.
  • Harassment - any unwanted conduct related to a protected characteristic that violates a person’s dignity or creates an intimidating, hostile, degrading, humiliating, or offensive environment.
  • Instruction to discriminate – directing or encouraging another person to discriminate against an individual or group based on a protected characteristic.
  • Victimisation – subjecting a person to adverse treatment because they have raised, supported, or participated in a complaint or process related to discrimination.

Retaliation – Any adverse action (including reduced opportunities, demotion, or termination) taken against an individual because they have exercised their rights, such as reporting misconduct, filing a complaint, participating in an investigation, or asserting labor rights.

Forced Labor – Any work or service which is exacted from any person under the menace of any penalty and for which the person has not offered themselves voluntarily.

Inhumane Treatment – Any act or practice that causes severe physical or mental suffering or violates a worker’s dignity, health, or safety

Equal Opportunity Employer – An organization that does not discriminate against employees or job applicants based on legally protected characteristics and provides equal access to employment opportunities. Protected characteristics include: race, color, and religion.

Sonoco’s Workplace and Labor Commitment

Sonoco is committed to protecting the dignity, safety, and rights of every employee by upholding internationally recognized human rights standards. We ensure fair and safe working conditions; prohibit child and forced labor; prevent discrimination, harassment, and retaliation; and respect employees’ freedom of association. These commitments are also detailed in Sonoco’s Code of Conduct Policy.

Fair And Safe Work

Sonoco believes workers should be treated with dignity, respect, and fairness and should not be subject to harassment, discrimination, retaliation, forced labor, or inhumane treatment. We compensate employees competitively relative to the industry and local labor market, and in accordance with terms of applicable collective bargaining agreements. We work to ensure full compliance with applicable wage, work hours, overtime, and benefits laws. 

The safety and health of Sonoco employees is top priority, and we take proactive measures to identify and mitigate workplace hazards while training employees to perform their duties safely. We are working continuously to provide a safe and inclusive work environment for our employees and contractors in line with international labor standards wherever we do business.

The Rights of Children and Abolition of Child Labor

Sonoco condemns the exploitation of children and forbids the unlawful use of children in our workforce. Sonoco does not recruit child labor and supports the elimination of exploitative child labor practices. Sonoco employees are required to be above the legal employment age in the country of their employment. 
Sonoco also supports laws duly enacted to prevent and punish the crime of sexual exploitation of children and will cooperate with law enforcement authorities in these matters. We encourage the creation of training or apprenticeship programs tied to formal education for young people, with appropriate policy governance and oversight.

Elimination of Forced or Compulsory Labor and Human Trafficking

Sonoco opposes the use of forced or compulsory labor, including prison labor, indentured labor, or modern forms of slavery and any form of human trafficking. Sonoco recruits its employees and provides working conditions, including payment of wages and benefits, that comply with applicable laws and regulations. No employee may be compelled to work through 
force or intimidation of any form.

Non-Discrimination

Sonoco is an Equal Opportunity Employer committed to providing its employees with a safe, non-discriminatory work environment that promotes open and honest communication and embraces dignity, respect, and diversity in all aspects of its business operations. Sonoco does not tolerate discrimination. We make it a priority to bring diversity and inclusiveness to Sonoco’s business and hiring practices by treating all of Sonoco’s employees (current and potential), stakeholders, and communities fairly, regardless of one’s race, gender, ethnicity, age, physical ability, religion, sexual orientation, or other applicable protected category. This statement is not limited to these statuses, but all statuses one may have.

We do not tolerate disrespectful or inappropriate behavior, unfair treatment, or retaliation of any kind. Harassment is not tolerated in the workplace or in any work-related circumstances outside of the workplace.

Freedom of Association and Collective Bargaining

Sonoco is committed to treating all employees fairly, with respect and dignity, and to providing competitive benefits and safe working conditions. A top priority is to minimize employee dissatisfaction and resolve issues or concerns in a timely manner. We encourage employees to utilize the open-door policy to openly communicate questions and suggestions with their management team.

Sonoco recognizes and respects its employees’ right to join associations and choose representative organizations for the purpose of engaging in collective bargaining in a manner consistent with applicable laws, rules, and regulations as well as local customs as appropriate. Where employees are represented by a legally recognized union, we are committed to establishing a constructive dialogue with their freely chosen representatives. Sonoco is committed to bargaining in good faith with such representatives

Sonoco’s Commitment to our Communities

Sonoco seeks to respect human rights and to develop an understanding of the cultures, customs, and values that prevail in our local communities by developing an inclusive and open dialogue with the people affected by our operations.

Respecting Indigenous Peoples Rights

Sonoco respects the cultures, customs, and values of the people in communities where we operate and strives to consider their needs, concerns, and aspirations. This includes protecting indigenous people’s traditions, water sources, and land.

Adopting Proportionate Security Arrangements

Sonoco strives to ensure that the provision of security to our operations and our engagement with public and private security forces is consistent with the laws of the relevant country and relevant international standards and guidelines.

Developing Practices for Land and Water Use

Sonoco works toward understanding and applying sound land and water use practices consistent with emerging international standards/principles and practices while respecting human rights.

Third-Party Expectations and Due Diligence

Sonoco is committed to identifying, mitigating, and responding to human rights risks across our operations and supply chain. To uphold this commitment, we maintain a structured due diligence framework that includes supplier onboarding, screening, and ongoing monitoring; internal compliance controls; participation in global responsible sourcing platforms; conflict minerals tracking; and established remediation processes. 

Because the conduct of our third-party partners reflects directly on Sonoco and our values, we work only with partners who share our commitment to responsible business practices and respect for human rights.

Supplier Screening

Designated Sonoco liaisons, responsible for managing supplier relationships, perform initial screening as our first line of defense. The Legal and Compliance Office supplements this through additional screening tools to identify and monitor our largest suppliers.

Onboarding

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. Under this Code, suppliers commit to conducting business in accordance with human rights principles and all applicable laws and regulations.

Third-Party Risk Management Program

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, and politically exposed persons, helps 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, requiring more detailed due diligence 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.

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. Because some products may contain these minerals, Sonoco conducts annual supply chain due diligence in alignment with SEC requirements and OECD guidance to determine whether any conflict minerals originate from high‑risk regions. These commitments and processes are detailed in Sonoco’s Conflict Minerals Policy and in our Form SD filings with the SEC.

Responding to Risks

Should Sonoco become aware of suspected risks of supplier human rights violations, we take further action. This may include requesting more human rights information via an extended questionnaire, conducting an audit, or reassessing the relationship.

Internal Due Diligence

Sonoco’s internal due diligence practices are designed to safeguard our workforce and uphold our commitment to human rights. Through responsible recruitment procedures and comprehensive employee training, we ensure that modern slavery risks are identified and prevented, and that employees understand their obligations under our Business Conduct Policies.

Employee Recruitment

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, all prospective employees are required to provide evidence of their legal right to work.

In North America (U.S. and Canada), temporary labor providers are centrally managed through standardized contracts and oversight processes. In other regions, Sonoco engages temporary labor providers through localized processes and applies appropriate expectations designed to support compliance with applicable legal and ethical standards, taking into account regional practices and levels of oversight.

Training

To reinforce a culture of compliance and ethical behavior, the Legal and Compliance Office administers mandatory annual Code of Conduct training for salaried employees. The curriculum covers key business ethics topics such as human rights, modern slavery, whistleblowing, protections against retaliation, and ethical standards of conduct. Training content is refreshed annually and incorporates relevant focus areas as appropriate. Employees must successfully complete knowledge assessments and attest to their review and understanding of the Company’s Business Conduct Policies.

Reporting Violations

Employees can raise concerns confidentially and without fear of retaliation. Sonoco provides multiple reporting channels through which employees and other Covered Persons can report concerns.

The Legal and Compliance Office (LCO) is responsible for receiving, investigating, and following up on reported concerns.

Reporting a Concern

Covered Persons may report concerns related to human rights, legal compliance, or business conduct by:

Employees may also contact their supervisors or speak to a Human Resources Representative.
Reports should include enough detail to support an objective and thorough investigation. Sonoco will investigate all concerns and take appropriate corrective action when alleged violations are substantiated.


Sonoco is committed to fostering a workplace where open and honest communication is valued. Managers are expected to maintain an environment in which questions and concerns can be raised without hesitation.

Confidentiality and Non-Retaliation

Sonoco strictly prohibits retaliation against anyone who reports a concern in good faith or participates in an investigation. Retaliation includes any adverse employment action taken as a direct result of raising a concern. This can include termination, demotion, or reduced opportunities.
Requests for anonymity will be respected to the extent possible without compromising the rights of others or the integrity of the investigation. Any individual who believes they are experiencing retaliation should immediately report it using the channels listed above.

Enforcement

Sonoco’s Legal and Compliance Office is accountable for ensuring compliance with the Policy and will review the Policy on an annual basis. Any significant changes to the policy will be communicated to Sonoco employees and relevant third parties in a timely manner. Management will ensure that the Sonoco personnel receive appropriate training if necessary.

Employees who fail to rectify a violation or who commit a serious breach of this Policy may be subject to disciplinary action, up to and including termination of employment and any additional sanctions as specified under applicable law. Third party partners or other Covered Persons who fail to correct a violation, refuse to cooperate, or commit a serious breach may be subject to termination of their relationship with Sonoco, as well as any other remedies available to Sonoco.

Questions

Questions concerning the content of this policy should be addressed to Sonoco’s Legal and Compliance Office at complianceoffice@sonoco.com .