Silgan Plastics LLC Supplier Code of Responsibility for Compliance with the CA Transparency in Supply Chains Act of 20110

Silgan Plastics LLC maintains a valuable reputation in the business community for honesty and fair dealing by acting ethically and in accordance with the laws applicable to its business.  It is Silgan’s expectation that each of its suppliers will likewise conduct its business in a legal and ethical manner.

The CA Transparency in Supply Chains Act of 2010 (“CA Law”) addresses issues of slavery and human trafficking, which are crimes under state, federal and international laws.  In support of this law, Silgan requires that its major manufacturing supplier comply with their obligations under the CA Law. Specifically, in supply agreements executed after the effective date of the CA Law by those suppliers covered by the law, Silgan requires certification of compliance with the CA Law, and certification that the supplier complies with laws regarding slavery and human trafficking in the countries in which the supplier produces its products.  Verification of such compliance is included in periodic contractual compliance audits that Silgan conducts of these suppliers.  At times of contract renewals, Silgan reviews the certifications from these suppliers as it assesses their performance and determines which suppliers it will continue to do business with. Silgan intends to conduct training sessions on a periodic basis for Silgan purchasing managers with respect to the CA Law.