Please see page 162 of our 2021 ESG Report for the statement from our CEO, Michael P. Doss.

https://www.graphicpkg.com/documents/2022/10/2021-esg-report.pdf#page=162

Please see our 2021 ESG Report for additional details on Graphic Packaging's approach to Human Rights.
https://www.graphicpkg.com/documents/2022/10/2021-esg-report.pdf/#page=162

As stated within our Human Rights policy, Graphic Packaging is committed to ensuring that people are treated fairly and with dignity and respect throughout the Company, its subsidiaries, in our supply chain and in the communities in which Graphic Packaging operates across the globe. The Company’s Core Values of Respect, Integrity, Teamwork, Relationships and Accountability form the foundation of our Code of Conduct, which applies to Graphic Packaging’s subsidiaries and affiliates and serves as a guideline as to how we engage with employees, customers, suppliers, and the community. The Company’s Code of Conduct and Human Rights Policy encompass the international human rights principles set forth in the UN Guiding Principles on Business and Human Rights, the Universal Declaration of Human Rights and its two corresponding covenants, the International Bill of Rights, the United Nations Conventions on the Rights of the Child, and the United Nations Convention on the Elimination of Discrimination against Women. Graphic Packaging’s approach to its business operations is informed by the OECD Guidelines for Multinational Enterprises, and the International Labor Organization’s 1998 Declaration on Fundamental Principles and Rights at Work, and the United Nationals Global Impact.

Also inspired by the 10 principles of the UNGC and the UN Guiding Principles on Business and Human Rights, our Global Supplier Code of Conduct (GSCOC) establishes clear expectations for upstream supply chain partners and invites them to join us in our commitment to work responsibly, with the needs of our stakeholders as our focus. We expect our suppliers (including vendors, contractors, agents, and other providers of goods and services) to fully comply with applicable laws and to adhere to internationally recognized ESG frameworks and standards covering ethical business practices, labor and human rights practices, and environmental stewardship. Our GSCOC also defines our supplier expectations for handling confidential information and for complying with conflict minerals laws and certifications. We expect our suppliers to use their best efforts to implement the standards outlined in our GSCOC with their suppliers and subcontractors throughout their own supply chain, and to seek our approval when they use subcontractors on our behalf.

In 2015, we embarked on a journey to integrate auditing our commitments to safety, the environment, human rights, and diversity using a single, comprehensive compliance program. We selected the Supplier Ethical Data Exchange (Sedex) platform, an on-line collaborative platform that allows us to screen for risks, complete annual self-assessments, document third-party social responsibility audits of our facilities, and share our social responsibility program and compliance results with our customers. Sedex has developed a rigorous 4-pillar auditing program that assesses a site based on the organization’s standards for labor, health and safety, environment and business ethics. All audits are conducted by a Sedex approved, independent third-party auditor. We initially set an ambitious plan to have every converting plant under our ownership for more than a year complete the four-pillar Sedex Member Ethical Trade Audit (SMETA) by the end of 2018, and then reaudit every three years or earlier. Starting with 2021, we are simplifying our reporting methodology and will be measuring compliance considering all converting facilities at year-end, regardless of acquisition date. Newly acquired converting facilities will be included in the auditing schedule, targeting highest risk locations first, and we will continue to report progress with the goal of achieving 100% compliance by 2025. Our converting facilities also use the Sedex platform to conduct annual self-assessment questionnaires (SAQs).

Additional information can be found in our 2021 ESG Report (www.graphicpkg.com/sustainability)

Please see our 2021 ESG Report for additional details on Graphic Packaging's approach to Human Rights.
https://www.graphicpkg.com/documents/2022/10/2021-esg-report.pdf/#page=162

Graphic Packaging applies the standards of the UNGC and the UN SDGs to our Code of Business Conduct and Ethics Policy (“Code”); our business ethics policies; our human resources policies; our worldwide health, safety and environment policy; and our supply chain sustainability program. We know our economic success contributes to the success of our employees and their families, our communities, and our partners around the world. By growing our business in a responsible way, we continue to challenge conventional packaging and contribute to a sustainable future. Our collaborative, creative, team members drive the change and innovation central to our success. We work diligently to create a safe environment for our employees, where workers’ and human rights are protected, and build a culture that embodies diversity, equity, and inclusion. We also work to ensure decent working conditions in our supply chains, without child labor or different forms of forced labor.

Graphic Packaging’s executive vice president, general counsel (EVPGC) and our compliance and risk committee are responsible for providing company-wide direction and oversight for our ethics program to ensure that all our employees exhibit behavior consistent with our core values. They establish appropriate ethics and compliance policies and procedures for the Company, which includes maintaining our Code. Policies are reviewed regularly, updated as necessary and approved by senior management, and our Board of Directors when appropriate. We measure the effectiveness of our human rights approach through progressing our Vision 2025 social responsibility ESG goal, annual compliance training completion rates, and through our ALERTline process.

Graphic Packaging conducts a tiered system of due diligence activities to identify and prevent human rights risks/impacts across our global business operations. We first screen countries where we have core business operations (e.g., HQ offices, mills, converting plants, and innovation centers) using the Sedex risk assessment tool Radar. The tool contains risk data based on independent and reputable sources that assess risks in the four SMETA pillars and 14 risk topics, including human and labor rights. Country risk indicators are drawn from publicly available sources and are chosen according to their coverage, reliability, comparability and relevance. Of the 129 locations reviewed (100% of our significant business operations locations), two ranked as potentially high-risk. These locations were recently acquired in 2021 and will undergo further assessment, including third-party SMETA audits, to screen for potential human rights impacts. The sites have been trained on our Code as part integration efforts, and to our knowledge no significant human rights risks are present at these locations. Furthermore, our converting plants use the Sedex platform to conduct annual self-assessments and every three years complete a social responsibility SMETA audit to check that they are compliant with applicable local, state, or national/regional requirements, as well as Graphic Packaging policies.

Each year, we use our on-line GPI University (GPI U) training platform to train our salaried employees on our Code, reminding them of our core values, policies prohibiting discrimination and harassment, and other business ethics policies. Code training for our hourly workforce is conducted in-person at our facilities, and training records are maintained locally. Additional ethics training is provided to employees, based on their job profile, to provide more comprehensive knowledge on potential risks related to individual job responsibilities (e.g., anti-corruption, antitrust, anti-harassment, anti-slavery/human trafficking awareness, human rights, etc.). New employees are provided a copy of our Code during onboarding and are required to acknowledge receipt of and compliance with our policies. They may also receive relevant ethics training, including anti-bribery training, based on their role in the Company. In addition, we review the Code and other relevant policies (e.g., insider trading, related party, the corporate governance guidelines, etc.) with all new Board members as part of their onboarding process.

Finally, Graphic Packaging’s multi-lingual ALERTline is available globally by phone or online 24 hours a day, seven days a week and is advertised in posters placed on bulletin boards in high traffic areas of our facilities. The ALERTline is operated by an independent company, providing a secure and confidential mechanism for raising concerns from employees, contractors, agents, distributors, business partners, and others. As allowed by local law, callers may remain anonymous. Any employee with questions about our human rights policy, reviews, or additional concerns can contact their local human resources representatives, the legal department, or our confidential ALERTline. Employees who raise concerns about potential misconduct are respected and retaliation against anyone reporting a potential violation is not tolerated. Graphic Packaging’s trained investigators review all allegations and conduct investigations and/or direct them to appropriate functions and/or teams for follow up. Anyone found in violation of our Code or who is dishonest during an investigation is subject to disciplinary action up to and including termination and/or legal action.

Additional information can be found in our 2021 ESG Report (www.graphicpkg.com/sustainability)

Please see our 2021 ESG Report for additional details on Graphic Packaging's approach to Human Rights.
https://www.graphicpkg.com/documents/2022/10/2021-esg-report.pdf/#page=162

Graphic Packaging’s Board and the Nominating and Corporate Governance Committee (“NCGC”) receive regular updates from senior management on potential environmental, social, and economic risks and opportunities, including climate; water; health, safety, and environmental (HSE); human capital and social issues; regulatory actions; and product stewardship matters. The NCGC also considers current and emerging social and environmental trends, as well as major legislative and regulatory developments and other public policy issues that may impact our business operations or stakeholders.

At Graphic Packaging, we formally measure the effectiveness of our human rights approach through progressing our Vision 2025 social responsibility ESG goal, annual compliance training completion rates, and through the ALERTline process.

Our Vision 2025 social responsibility goal is that our converting plants use the Sedex platform to conduct annual self-assessments and every three years undergo a SMETA audit to check that they are compliant with applicable local, state, or national/regional requirements, as well as Graphic Packaging policies. At year-end 2021, 71% of converting plants were compliant with completing their third-party SMETA audit on schedule. The decrease in compliance rates relative to 2020 (91%) is due to the Americraft and AR Packaging acquisitions completed in 2021. Historically, the Company has reported goal progress only for facilities owned by Graphic Packaging for one year or longer. Starting with 2021, we are simplifying our reporting methodology and will be measuring compliance considering all facilities at year-end, regardless of acquisition date. Newly acquired facilities will be included in the auditing schedule, targeting highest risk locations first, and we will continue to report progress with the goal of achieving 100% compliance by 2025.

In 2021, 97% of global salaried employees completed Code training, 97% completed the anti-harassment training, 89% completed the anti-bribery training, and 90% completed modern slavery training, demonstrating good reach across our global salaried employees. Hourly employee training rates are lower due to challenges associated with administering in-person training and ability to document local training records.

Finally, 100% of calls made to the ALERTline in 2021 were investigated and closed on time, with 98% of investigated calls closed by December 31, 2021. For total investigated cases, 8% of matters were substantiated (in whole or in part) and the remainder were either unsubstantiated or not related to policy violations. Types of issues reported to the ALERTline in 2021 included conflicts of interest; health, safety, and environmental issues; misconduct; and others. All reported substantiative issues were investigated and closed within 30 days or less following our prioritization hierarchy, and appropriate corrective action was taken for substantiated matters. Graphic Packaging’s trained investigators review all allegations and conduct investigations and/or direct them to appropriate functions and/or teams for follow up. Investigations are prioritized based on the potential severity of the allegation and are completed within 90 days of being reported. Confidentiality is essential to maintain the integrity of the investigation and those who participate in good faith are protected from retaliation. The investigation team, led by human resources, conducts root-causes analysis of all substantiated instances of ethical misconduct to understand underlying causes and prevent reoccurrence. Appropriate business leaders, human resources, and experienced ethics and compliance professionals review substantiated violations of the Code to ensure a fair and consistent disciplinary response to confirmed violations of the Code. These violations are also shared with the Board. Following the investigation review, an appropriate response is implemented, which could include measures such as training, policy revisions, disciplinary action, etc. Anyone found in violation of our Code or who is dishonest during an investigation is subject to disciplinary action up to and including termination and/or legal action.

Please see our 2021 ESG Report for additional details on Graphic Packaging's approach to Labor.
https://www.graphicpkg.com/documents/2022/10/2021-esg-report.pdf/#page=162

Graphic Packaging is committed to ensuring that people are treated fairly and with dignity and respect throughout the Company, its subsidiaries, in our supply chain and in the communities in which Graphic Packaging operates across the globe. We are committed to protecting human rights throughout our global operations, and we respect the human rights of all people in the communities where we operate and in our supply chain. Human rights include equality among people, employee well-being and security, personal freedom from persecution, privacy, and economic, social and cultural freedom. The Company’s Code and Human Rights Policy encompass the international human rights principles set forth in the UN Guiding Principles on Business and Human Rights, the UN Universal Declaration of Human Rights and its two corresponding covenants, the International Bill of Rights, the United Nations Conventions on the Rights of the Child, and the United Nations Convention on the Elimination of Discrimination against Women. Graphic Packaging’s approach to its business operations is informed by the OECD Guidelines for Multinational Enterprises, the ILO’s 1998 Declaration on Fundamental Principles and Rights at Work, and the UNGC. We strive to create a working environment for all employees that fosters a spirit of respect, trust, accountability, and teamwork — and we encourage our vendors and suppliers to do the same. To promote that environment in all our workplaces around the world, we have defined business practices that support human rights.

Per our Code of Conduct, Child Labor and Remediation Policy, and Human Rights Policy, and as it relates to Principles 3-6, we recognize and respect our employees’ right to choose whether or not to join a labor union, participate privately in trade associations and collectively bargain in accordance with local or national law. We do not knowingly engage in forced, compulsory or bonded labor and we do not threaten workers or restrict their movement. We do not employ workers in violation of any applicable national or local regulation governing age of employment. In addition, we do not employ workers in violation of the mandatory school age set by a country. We do not discriminate based on national or ethnic origin, place of residence, gender, gender identity, sexual orientation, pregnancy, color, religion, ancestry, age, disability, marital status, genetic information, political affiliation, veteran/military status, and any other status protected by applicable law. This applies to anyone we employ or do business with, as well as anyone who applies for employment with us. We are committed to providing a work environment that encourages and promotes wellness and safety for our employees, contractors, suppliers, visitors, and neighboring communities.

Graphic Packaging conducts a tiered system of due diligence activities to identify and prevent human rights risks/impacts across our global business operations. We first screen countries where we have core business operations (e.g., HQ offices, mills, converting plants, and innovation centers) using the Sedex risk assessment tool Radar. The tool contains risk data based on independent and reputable sources that assess risks in the four SMETA pillars and 14 risk topics, including human and labor rights. Country risk indicators are drawn from publicly available sources and are chosen according to their coverage, reliability, comparability and relevance. Of the 129 locations reviewed (100% of our significant business operations locations), two ranked as potentially high-risk. These locations were recently acquired in 2021 and will undergo further assessment, including third-party SMETA audits, to screen for potential human rights impacts. The sites have been trained on our Code as part integration efforts, and to our knowledge no significant human rights risks are present at these locations. Furthermore, our converting plants use the Sedex platform to conduct annual self-assessments (SAQs) and every three years complete a social responsibility SMETA audit to check that they are compliant with applicable local, state, or national/regional requirements, as well as Graphic Packaging policies.

As part of our 2025 social responsibility ESG vision, we have set a goal that 100% of our global converting plants will be in compliance with a social responsibility audit within three years. Our Vision 2025 safety goal is to continue progress towards our aspirational target of zero safety incidents, ensuring that safety remains a top priority as well a reducing our lost time injury rate (LTIR) to 0.2. We also measure the effectiveness of our human rights approach through annual compliance training completion rates and through our ALERTline process. Any employee with questions about our human rights policy, reviews, or additional concerns can contact their local human resources representatives, the legal department, or our confidential ALERTline.

Please see our 2021 ESG Report for additional details on Graphic Packaging's approach to Labor.
https://www.graphicpkg.com/documents/2022/10/2021-esg-report.pdf/#page=162

Our governance system is underpinned by our Company values, Code of Conduct (“Code”), and strong corporate policies that embrace the principles of the UN Global Compact, various external global frameworks, and comply with the local laws and regulations in the regions in which we operate. In addition, our Equal Employment Opportunity Policy describes our approach to treat all employees fairly, protect against discrimination, and provide accommodations for employee needs. Through our policies, we set behavioral expectations for our global workforce. Any employee with questions about our human rights policy, reviews, or additional concerns can contact their local human resources representatives, the legal department, or our confidential ALERTline. The multi-lingual ALERTline is available globally by phone or online 24 hours a day, seven days a week and is advertised in posters placed on bulletin boards in high traffic areas of our facilities. In addition, the Company provides business partners information on accessing the ethics hotline during our contracting process. The ALERTline is operated by an independent company, providing a secure and confidential mechanism for raising concerns from employees, contractors, agents, distributors, business partners, and others.

Our executive vice president, general counsel (EVPGC) and our compliance and risk committee are responsible for providing company-wide direction and oversight for our ethics program to ensure that all our employees exhibit behavior consistent with our core values. They establish appropriate ethics and compliance policies and procedures for the Company, which includes maintaining our Code. The Code was last updated in May 2022 and compliance with the Code is regularly reviewed by the Graphic Packaging ELT and the Board. Our top leaders, including our Board, are committed to helping every Graphic Packaging employee act with integrity — whether they be full-time, part time, temporary employees, or interns. Each year, we use our on-line GPI University (GPI U) training platform to train our salaried employees on our Code, reminding them of our core values, policies prohibiting discrimination and harassment, and other business ethics policies. Code training for our hourly workforce is conducted in-person at our facilities, and training records are maintained locally. Additional ethics training is provided to employees, based on their job profile, to provide more comprehensive knowledge on potential risks related to individual job responsibilities (e.g., anti-corruption, antitrust, anti-harassment, anti-slavery/human trafficking awareness, human rights, etc.). New employees are provided a copy of our Code during onboarding and are required to acknowledge receipt of and compliance with our policies.

Graphic Packaging employs a layered approach to our Health, Safety and Environment (HSE) global efforts, beginning with our HSE core values and expectations. The health and safety of our employees and the public, and the quality of our environment means minimizing to the extent possible health, safety and environmental risks. Our HSE team provides leadership for business units to implement effective standards to protect our employees, contractors, neighboring communities, and the environment. We have implemented minimum safety expectations (MSEs) across our operations, globally. Graphic Packaging’s MSE’s are a combination of cultural and programmatic elements designed to take a facility-wide approach to managing HSE risks through effective implementation of risk reduction and technical programs.

In 2021, Graphic Packaging established a cross-functional labor council that consists of the executive vice president, human resources (EVPHR); the vice president, labor relations; the vice president, chief employment counsel; the director of benefits; senior leaders from each business unit; and their respective human resources business partners. The labor council reviews the Company’s collective bargaining strategies and the status of all collective bargaining agreements, including those that may have expired, are undergoing negotiation, or are nearing negotiation. They also monitor wage and benefit offerings and external labor trends and events that could impact our labor relations strategy.

Furthermore, in 2021, we implemented the following enhancements to our ethics and compliance program:
• Revised our Code and translated it into multiple new languages to make it accessible for our ~5,000 new employees across Europe and Asia.
• Expanded our global privacy policy and completed training initiatives.
• Developed new Human Rights Policy and distributed to all global managers.
• Continued to address moderate- to low-risk improvement opportunities identified in the General Data Protection Regulation (GDPR) audit.
• 100% of global business operations sites are risk assessed concerning business ethics issues.
• Conducted in-person training with commercial teams on email best practices.
• Completed enterprise fraud and cybersecurity risk assessments.
• Established a third-party risk management committee comprised of Legal, IT, Cyber Security, Supply Chain, Internal Audit, HSE, Procurement, and business representation.

Please see our 2021 ESG Report for additional details on Graphic Packaging's approach to Labor.
https://www.graphicpkg.com/documents/2022/10/2021-esg-report.pdf/#page=162

At Graphic Packaging, we’ve developed an intentional approach to build a cohesive, inclusive workplace environment that supports our globally diverse employees. Our approach respects cultural differences, treats everyone with dignity, and commits to equal employment opportunity and nondiscriminatory practices in hiring, training, and compensating our employees. We foster inclusion through the Company’s four employee-led business resource groups (BRGs). Our BRGs honor the unique cultural experiences of groups within our employee population. By offering a venue for conversation and connection, these groups build communities within our Company, allowing members to share experiences and resources and pursue personal and professional development. Each group sponsors events and initiatives to build awareness and value for our unique talents and cultural backgrounds, supports community engagement, and celebrates our diversity. As of January 31, 2022, our US workforce was made up of 21% women (23% globally) and 29% ethnically diverse employees versus the pulp/paper industry benchmarks of 28% and 17% respectively (US Bureau of Labor Statistics, 2020). Furthermore, 40% of our executive team was ethnically diverse. In 2021, we accelerated our focus on increasing women representation in leadership positions and launched our women in leadership development experience. During the first half of 2022, we also increased representation of women on our executive team, with women now making up 33% of our executive leadership team. Our leadership team facilitates an environment where inclusion is modeled and cascaded through our organization. In 2021, 97% of global salaried employees completed Code training, 97% completed the anti-harassment training, 89% completed the anti-bribery training, and 90% completed modern slavery training, demonstrating good reach across our global salaried employees. Completion rates for hourly employees were lower (39% for Code and 36% for anti-harassment training) due to challenges administering the in-person trainings during the COVID-19 pandemic and to limitations in aggregating local training records. We are planning to include our hourly employees in future deployments of the GPI U training platform, which will improve our ability to offer and track training compliance with this employee group.

With regards to freedom of association and the right to collective bargaining, we believe it is important Graphic Packaging to maintain strong, positive relationships with the unions or work councils who represent our employees and to bargain fairly with those representatives to maintain optimal operations globally. A majority of our approximately 24,000 employees globally are represented by labor unions, collective bargaining agreements, and/or work councils. In the United Sates, approximately 44% of employees belong to a labor union. Globally, that number rises to approximately 52% of all employees belonging to a labor union, with 20% of employees covered by a work council (includes some union employees) and approximately 53% of employees who are covered by formally elected employee representatives. Most union/represented employees are hourly, full time, permanent production employees working in Graphic Packaging mills and converting plants.
Furthermore, at year-end 2021, 71% of converting plants were compliant with completing their third-party SMETA audit on-schedule. The decrease in compliance rates relative to 2020 (91%) is due to the Americraft and AR Packaging acquisitions completed in 2021. Historically, the Company has reported goal progress only for facilities owned by Graphic Packaging for one year or longer. Starting with 2021, we are simplifying our reporting methodology and will be measuring compliance considering all facilities at year-end, regardless of acquisition date. Newly acquired facilities will be included in the auditing schedule, targeting highest risk locations first, and we will continue to report progress with the goal of achieving 100% compliance by 2025.

Appropriate business leaders, human resources, and experienced ethics and compliance professionals review substantiated violations of the Code to ensure a fair and consistent disciplinary response to confirmed violations of the Code. These violations are also shared with the Board. Following the investigation review, an appropriate response is implemented, which could include measures such as training, policy revisions, disciplinary action, etc. Anyone found in violation of our Code or who is dishonest during an investigation is subject to disciplinary action up to and including termination and/or legal action. 100% of calls made to Graphic Packaging’s ALERTline in 2021 were investigated and closed on time, with 98% of investigated calls closed by December 31, 2021. For total investigated cases, 8% of matters were substantiated (in whole or in part) and the remainder were either unsubstantiated or not related to policy violations. Types of issues reported to the ALERTline in 2021 included conflicts of interest; health, safety, and environmental issues; misconduct; and others. All reported substantiative issues were investigated and closed within 30 days or less following our prioritization hierarchy, and appropriate corrective action was taken for substantiated matters.

Please see our 2021 ESG Report for additional details on Graphic Packaging's approach to Environment.
https://www.graphicpkg.com/documents/2022/10/2021-esg-report.pdf/#page=162

Graphic Packaging is committed to operating responsibly, in line with our five corporate values, Code of Conduct (Code), and the 10 principles of the United Nations Global Compact (UNGC). We seek to apply manufacturing processes or practices that create less environmental impact, and through our product innovation practices, manage potential risks or impacts from our products throughout their entire life cycle, from the design stage to product end-of-life.

Our Global Supplier Code Of Conduct (GSCOC) and Sustainable Forestry Policy outline our commitment to uphold human, civil, and traditional rights, including those of indigenous peoples, protect rare and imperiled species and ecosystems, avoid the use of genetically modified organisms (GMOs), and avoid wood that was illegally harvested or results from conversion of forests to other land uses or nonnative plantations. These documents reflect Graphic Packaging’s values, align with our company’s broader Code, and reinforce our commitment to uphold the US Lacey Act and the European Union Timber Regulation. These laws address illegal logging and prohibit trafficking of illegally harvested products while protecting the competitiveness of legally harvested trees. We assess wood supplier conformance to our Sustainable Forestry Policy using supplier risk assessments and field audits. Our Due Diligence System (DDS) provides the framework for completing risk assessment evaluations on each supplier that delivers wood fiber to our facilities. Our field tract inspection audits are conducted on suppliers during harvesting activities to verify supplier compliance with our Sustainable Forestry Policy and local best management practices. We complete risk assessments on all new wood suppliers and target and have set a target of auditing 50% of our existing wood suppliers each year, with a goal of having all suppliers audited at least once every two years. We have also set a goal that our own facilities will be compliant with a fiber certification standard such as those from the Sustainable Forestry Initiative (SFI) or the Forest Stewardship Council (FSC). These certification standards set expectations for sustainable forest management, harvesting practices and sourcing practices with the common objective to protect sensitive ecosystems, preserve biodiversity, and prevent forest loss.

Graphic Packaging embraces continuous learning and improvement as we evolve our forest sustainability approach and drive positive impacts through our programs. Our forest fiber sourcing programs are audited annually by both internal auditors and by accredited, external third-party auditors, and audit findings are logged and tracked through completion. The results of these audits, along with our Sustainable Forestry Policy, are reviewed annually with Graphic Packaging leaders to ensure that appropriate resource allocations and investments are made to grow our sustainable forestry programs and drive positive impacts through our sourcing practices.

We recognize that the packaging sector plays a central role in the transition to a low-carbon economy due to the current and future demand for recyclable packaging made from renewable, non-fossil-based materials. Our Vision 2025 planet goals challenges us to reduce our use of natural resources, greenhouse gas emissions, and operations environmental footprint while increasing fiber recovery and paperboard circularity. We know we must reduce our own emissions while influencing our value chain to do the same. Graphic Packaging values collaboration to drive change and works with policymakers, our value chain, and other organizations to encourage collective action to reduce GHG emissions and the commercial development and use of lower-carbon forms of energy. We have formalized our commitment to reduce our emissions through our Vision 2025 climate goals: to reduce GHG emissions intensity by 15% and to reduce our nonrenewable energy intensity by 15%, both against a 2016 baseline. We also have committed to setting a near-term Science Based Target. Additional Vision 2025 Planet Goals include reducing mill effluent intensity by 15% and driving out waste in our global operations.

Please see our 2021 ESG Report for additional details on Graphic Packaging's approach to Environment.
https://www.graphicpkg.com/documents/2022/10/2021-esg-report.pdf/#page=162

Graphic Packaging has a multipronged approach toward preventing and mitigating occupational health and safety impacts linked by business relationships, which includes an established product stewardship program to ensure that health, safety and environmental (HSE) protection is an integral part of designing, manufacturing, marketing, distributing, using, recycling, and disposing of our products.

Our Vision 2025 planet goals challenge us to reduce our use of natural resources, greenhouse gas emissions, and operations environmental footprint while increasing fiber recovery and paperboard circularity. As demand for recycled fiber packaging increases, there is a need to further close the fiber loop by increasing paper recovery rates. We are engaged at both ends of the recovered material value stream — improving fiber circularity by promoting paper recycling and then using recovered materials to reduce dependence on virgin fiber in our products. We have set four goals which focus on GHG emissions intensity reductions, nonrenewable energy intensity reductions, effluent intensity reductions, as well as operational waste reductions. These reduction actions are guided by our values, Code, and Worldwide Health, Safety, and Environment policy. We view energy use and GHG emissions as inextricably linked and tackle reducing nonrenewable energy use as a key lever in reducing our scope 1 and scope 2 GHG emissions. Our teams are focused on improving energy efficiency in our operations, increasing our use of renewable energy, acting on opportunities to deploy lower energy/emission technologies at our manufacturing sites, and optimizing our manufacturing footprint. Examples of this include use of renewable biomass energy at our virgin mills; exploration of solar, wind and other renewable power options; use of engineering software to optimize the energy balance and identify improvement opportunities to lower energy use; and participation in cross-industry collaborative programs like the US Department of Energy Better Plants program.

Our chief sustainability officer (CSO) works with the executive vice president (EVP) mills and leaders from our converting operations on establishing and actioning our climate strategy. They are accountable for monitoring external trends, assessing climate-related opportunities and risks, allocating resources to action the climate strategy, and providing regular updates to the executive leadership team (ELT) and Board. The ESG data manager works closely with the operations teams, our Center of Excellence (COE), and supply chain team to ensure energy and GHG data and metrics are timely, accurate, and effective for communicating our environmental performance and impact.

Our vice president, HSE (VPHSE) provides corporate oversight and guidance to our global sites and facilitates sharing learnings and best practices. Each operating location is responsible for implementing and maintaining an environmental compliance program, tailored to the regulatory requirements and operational needs of the site. The site manager is accountable for compliance. The VPHSE provides assistance, as needed, to ensure our sites remain in material compliance with regulatory requirements and any assigned corrective actions are completed on schedule. The VPHSE provides periodic updates on our operation’s environmental compliance programs to the executive leadership team and Board. Graphic Packaging employees are provided with environmental training to understand general and task-specific environmental compliance-related operating procedures. Employees are encouraged to report any conditions or potential conditions that could result in a non-permitted spill or release of a hazardous substance to the environment — even if the employee believes the problem is corrected. Our operations are trained to address any spills or releases immediately and to contact local regulatory agencies as applicable per local requirements.

From our suppliers, we expect reliability, quality, and service as well as innovation, flexibility, a partnership mindset, alignment with our values, and a commitment to operate safely and responsibly. Our aim is to choose suppliers that add value in a way that contributes to our Company’s long-term success and sustainable growth. Our Sustainable Forestry Policy describes expectations for wood buyers and suppliers regarding how they source, harvest, and deliver wood fiber to our mills. In addition, contracts with wood and wood chip suppliers require their commitment to avoid highest risk and most controversial virgin wood sources. For example, Graphic Packaging helps develop wood supplier knowledge and awareness of sustainable forest management practices by financially supporting logger training and continuing education programs for our wood suppliers. These trainings are offered through independent third parties in coordination with individual state Sustainable Forestry Initiative Implementation Committees (SICs). Training records are maintained and verified on the respective organizations’ websites. Our wood procurement professionals serve on individual state SIC teams to stay informed of current and evolving forest management issues and remain prepared to update our wood supplier management practices.

Please see our 2021 ESG Report for additional details on Graphic Packaging's approach to Environment.
https://www.graphicpkg.com/documents/2022/10/2021-esg-report.pdf/#page=162

In regard to our 2025 Vision ESG planet goals, in 2021, 91% of converting plant waste was successfully diverted to recycling/beneficial reuse and away from disposal via landfill, incineration, or other disposal method; 95% of reported paper waste generated by Graphic Packaging facilities was recovered and recycled; and renewable fuels represented almost 70% of our total fuel mix and supplied 66% of our global energy needs.

Graphic Packaging plans for the possibility that incidents may occur and that our sites are ready to respond to emergency situations. Our sites develop local emergency response plans that address risks to their specific locations, such as fire, medical, weather, natural disasters, security incidents, workplace violence, and other locally relevant topics. Site leadership is accountable for the success of each site’s emergency response program. We have also implemented minimum safety expectations (MSEs) across our operations, globally. Our culture elements focus on management leadership, training, HSE resources, and behavioral based efforts. Programmatic elements are designed to reduce risk in our operations through implementing technical HSE programs consistently across our business. This continuous improvement approach led by our operational leaders, drives our HSE culture of caring and engaging employees.

The Company paid no environmental regulatory fines in 2021, and there were no incidents of noncompliance that resulted in a formal enforcement action. We track and investigate any incidents that result in a release to the environment, and where needed, make improvements to guard against future recurrences. In 2021, there were no significant spills resulting in serious injury or a significant impact on the environment, nor were there incidents of non-compliance associated with water quality permits, standards and regulations.

We identify supplier sustainability issues through ethics hotline reports, industry sources, or those self-reported by suppliers. We thoroughly review significant supplier sustainability issues within our supply chain to identify root causes and develop effective remediation actions to prevent recurrence. Examples of potential significant supplier sustainability issues may include unsafe work conditions, child or forced labor, bribery and corruption, regulatory violations, environmental damages, etc. In 2021, no significant supplier environmental or social incidents were reported. In addition, we target auditing 50% of our wood suppliers each year to assess compliance with our Forest Sustainability Policy and local forestry best management practices. In 2021, we completed audits with 112% of targeted wood suppliers (56% of total wood suppliers were audited versus the 50% target). No significant supplier environmental or social concerns were identified during the audits.

We demonstrate the performance of our HSE program through monthly environmental compliance reporting and by periodically conducting environmental compliance audits (either second and third-party audits) at our manufacturing locations. As of December 31, 2021, 23 Graphic Packaging locations (20%) are certified to ISO 14001. Each of our operating sites submit a monthly environmental compliance report to corporate HSE, identifying non-compliance issues incurred during the reporting period. We use a HSE data management tool to track and document operating site monthly environmental compliance reports, track audit status and track ongoing environmental audits, including audit findings, corrective actions and completion status. The tool is also used to track site environmental delegation of authority letters are in place, as well as current active permits, regulatory inspections, notice of violations, consent orders, Occupational Safety and Health Administration (OSHA) citations, complaints received from regulatory agencies, and site Resource Conservation and Recovery Act (RCRA) information. Sites use the compliance calendar to set reminders for critical environmental reports and permit renewal timelines. The corporate HSE team performs periodic reviews and data quality assurance checks of the site-entered information to verify compliance activities. Our vice president, HSE (VPHSE) provides corporate oversight and guidance to our global sites and facilitates sharing learnings and best practices. The VPHSE also provides periodic updates on our operation’s environmental compliance programs to the executive leadership team and Board.

Please see our 2021 ESG Report for additional details on Graphic Packaging's approach to Anti-Corruption.
https://www.graphicpkg.com/documents/2022/10/2021-esg-report.pdf/#page=162

Graphic Packaging conducts multiple risk assessments each year on enterprise, financial, and operational site systems to determine potential overarching risks to the Company and aligns the scope of assessments, reviews, and/or audits over the quality of compliance and risk management programs with identified higher risk areas. These risk assessments include risks from corruption, bribery, and other ethical business practices. In addition, a fraud risk assessment is performed no less than every three years, and the Fraud Risk Management Program is updated based on its results.

Our commitment to integrity means we all play a part in the effort to eliminate bribery and corruption worldwide. We follow anti-bribery and anti-corruption laws and expect our business partners to do the same. Our Code of Conduct (Code), Global Supplier Code of Conduct (GSCOC), and Anti-Bribery and Anti-Corruption Policy reflect the principles set forth in the UN Convention against Corruption and the UNGC. Our Anti-Corruption Policy provides definitions on what constitutes a bribe, discusses the ways employees may encounter demands for bribes and/or extortion, makes clear to employees that we do not engage in bribery under any circumstances, and assures employees that they will not suffer negative consequences for refusing to pay a bribe. These expectations are reinforced through targeted ethics training to all salaried employees, including our ELT and top 100 company leaders on a regular basis.

The Company shares our expectations to operate ethically with our suppliers through our GSCOC and contractual obligations requiring our relevant business partners to comply with anti-bribery laws. The GSCOC is made available to all suppliers through our supplier portal, and we include our expectation to comply with the GSCOC during the supplier onboarding process and in contract terms and conditions for our North America suppliers.

The Corruption Perception Index is used annually to risk rank all operating locations for compliance risks. Locations ranked with higher corruption risk are audited by Internal Audit. When a country is flagged based on screening indices, a focused review is conducted using both quantitative and qualitative factors. The internal audit team then determines the need to perform audit activities. Audit activities over corruption and bribery have been performed at locations in China, Mexico, Indonesia, Nigeria, Brazil, and Poland. All audit activities resulting in observations are tracked to closure. In addition, key strategic areas or risks identified in the enterprise risk assessment are owned by a senior executive, along with action plans and due dates that are monitored throughout the year. The executive vice president, general counsel (EVPGC) and compliance and risk committee regularly review our global operations footprint to evaluate potential corruption or fraud risk across our operations. This is an ongoing process conducted through quarterly committee reviews and an annual formal compliance assessment led by the EVPGC and presented to the Board. Graphic Packaging has certification processes in place through internal/external audit processes, as well as robust internal controls to ensure accurate accounting practices.

Employees who have ethics concerns or want to report a possible violation can anonymously contact the ALERTline via web reporting, email or phone 24 hours a day, seven days a week.

Please see our 2021 ESG Report for additional details on Graphic Packaging's approach to Anti-Corruption.
https://www.graphicpkg.com/documents/2022/10/2021-esg-report.pdf/#page=162

Our Anti-Corruption Policy makes clear to employees that we do not engage in bribery under any circumstances and assures employees that they will not suffer negative consequences for refusing to pay a bribe. Due diligence guidelines and procedures are included in the Anti-Corruption Policy. These expectations are reinforced through targeted ethics training. Any employee having information or knowledge of any actual or contemplated violation of Company Policies shall promptly inform their supervisor, report the matter to our General Counsel, or call our 24/7 ALERTline or visit the Alertline website to report the matter.

Each year, we use our on-line GPI University (GPI U) training platform to train our salaried employees on our Code, reminding them of our core values, policies prohibiting discrimination and harassment, and other business ethics policies. Code training for our hourly workforce is conducted in-person at our facilities, and training records are maintained locally. Additional ethics training is provided to employees, based on their job profile, to provide more comprehensive knowledge on potential risks related to individual job responsibilities. For example, Graphic Packaging provides focused training on anti-corruption/anti-bribery topics to all salaried employees, including our ELT and top 100 company leaders on a regular basis. New employees are provided a copy of our Code during onboarding and are required to acknowledge receipt of and compliance with our policies. In addition, we review the Code and other relevant policies (e.g., insider trading, related party, the corporate governance guidelines, etc.) with all new Board members as part of their onboarding process.

The Company also shares our expectations to operate ethically with our suppliers through our GSCOC and contractual obligations requiring our relevant business partners to comply with anti-bribery laws. The GSCOC is made available to all suppliers through our supplier portal, and we include our expectation to comply with the GSCOC during the supplier onboarding process and in contract terms and conditions for our North America suppliers.

Our EVPGC and the compliance and risk committee — composed of the EVPGC and executives in human resources, legal, IT, health and safety, and internal audit — are responsible for developing and administering the ethics and compliance program. The committee periodically reviews Company ethics and compliance statistics, conducts periodic risk assessments and internal audits, monitors trends, and assess the effectiveness of our ethics and compliance programming. The EVPGC reports monthly on legal and compliance matters to the executive leadership team and quarterly to the Audit Committee on the Company’s ethics and compliance initiatives and related metrics, including reports on all alleged material violations of the Code. Each November, the EVPGC (on behalf of the compliance and risk committee) reports to the Board on all aspects of the compliance program, including progress made on goals set the prior year as well as planned activities and goals for the coming year.

In 2021, we implemented a number of enhancements to our ethics and compliance program including, but not limited, to the following: Revised our Code and translated it into multiple new languages to make it accessible for our ~5,000 new employees across Europe and Asia; Expanded our global privacy policy and completed training initiatives; Developed new Human Rights Policy and distributed to all global managers; Continued to address moderate- to low-risk improvement opportunities identified in the General Data Protection Regulation (GDPR) audit; 100% of global business operations sites are risk assessed concerning business ethics issues; and Established a third-party risk management committee comprised of Legal, IT, Cyber Security, Supply Chain, Internal Audit, HSE, Procurement, and business representation.

Please see our 2021 ESG Report for additional details on Graphic Packaging's approach to Anti-Corruption.
https://www.graphicpkg.com/documents/2022/10/2021-esg-report.pdf/#page=162

We measure the effectiveness of our ethics and compliance (E&C) management approach by tracking the annual completion rates for assigned ethics trainings and by tracking investigation completion rates for calls to our ALERTline. In addition, we have internal controls to audit and assess our E&C processes, and we look for opportunities to improve our systems and compliance performance. Improvement opportunities and/or corrective actions identified through audits and/or incident investigation processes are documented and tracked through completion. We believe our internal controls are effective in maintaining and advancing a robust E&C management system and, as such, we do not currently seek external certification of our system. The EVPGC reports monthly on legal and compliance matters to the executive leadership team and quarterly to the Audit Committee on the Company’s ethics and compliance initiatives and related metrics, including reports on all alleged material violations of the Code. Each November, the EVPGC (on behalf of the compliance and risk committee) reports to the Board on all aspects of the compliance program, including progress made on goals set the prior year as well as planned activities and goals for the coming year.

In 2021, we implemented a number of enhancements to our ethics and compliance program including, but not limited, to the following: Revised our Code and translated it into multiple new languages to make it accessible for our ~5,000 new employees across Europe and Asia; Expanded our global privacy policy and completed training initiatives; Developed new Human Rights Policy and distributed to all global managers; Continued to address moderate- to low-risk improvement opportunities identified in the General Data Protection Regulation (GDPR) audit; 100% of global business operations sites are risk assessed concerning business ethics issues; and Established a third-party risk management committee comprised of Legal, IT, Cyber Security, Supply Chain, Internal Audit, HSE, Procurement, and business representation.

Any employee who violates any applicable law, or who violates any related GPI policy or procedure, will be subject to appropriate disciplinary action, up to and including termination. In some cases, GPI policy or procedure may be more stringent than a local law. GPI employees must still comply with the GPI policy or procedure in such instances. Any employee who is aware of another employee’s violation of such laws, policies, or procedures but does not report same, will also be subject to appropriate disciplinary action. No employees will be penalized for reporting any concern or suspicion they have about corrupt behavior. Any employee having information or knowledge of any actual or contemplated violation of this Policy shall promptly inform their supervisor, report the matter to our General Counsel, call our ALERTline or visit the Alertline website to report the matter.

There were no confirmed cases regarding bribery that involved employees or business partners in 2021. 100% of calls made to the ALERTline in 2021 were investigated and closed on time, with 98% of investigated calls closed by December 31, 2021. For total investigated cases, 8% of matters were substantiated (in whole or in part) and the remainder were either unsubstantiated or not related to policy violations. Types of issues reported to the ALERTline in 2021 included conflicts of interest; health, safety, and environmental issues; misconduct; and others. All reported substantiative issues were investigated and closed within 30 days or less following our prioritization hierarchy, and appropriate corrective action was taken for substantiated matters.

Furthermore, in 2021, 97% of global salaried employees completed Code training, 97% completed the anti-harassment training, 89% completed the anti-bribery training, and 90% completed modern slavery training, demonstrating good reach across our global salaried employees. 100% of global salaried employees received our “trade sanctions compliance memo.” Completion rates for hourly employees were lower (39% for Code and 36% for anti-harassment training) due to challenges administering the in-person trainings during the COVID-19 pandemic and to limitations in aggregating local training records. We are planning to include our hourly employees in future deployments of the GPI U training platform, which will improve our ability to offer and track training compliance with this employee group. Antitrust training was also provided in-person to our global commercial teams during their annual sales team meetings. We are exploring adding antitrust training to our on-line training program in the future.