Code of Conduct
The MWV Code of Conduct presents the standards of conduct for all employees. MWV employees should direct any questions about the Code of Conduct to their supervisor, human resources manager, senior management or to a member of the Law Department. Employees may also submit questions, concerns or report any suspected misconduct through the MWV Ethics Line at +1 (800) 457-6435 or by email to ethics@mwv.com.
To All MWV Employees:
I. Safety
We all share in the responsibility to maintain a safe work environment. MWV has developed comprehensive safety and health plans and programs for each manufacturing and production facility. Working together, we believe we can prevent all workplace injuries and occupational illnesses.
Employees are expected to comply fully with health and safety regulations and to strive to improve our safety performance. Employees must report immediately any unsafe work conditions to their supervisor or to the safety director for the location.
To protect the safety and health of its employees, MWV does not tolerate alcohol or drug abuse. All employees must report to work free from the influence of any substance that could reduce safety or affect performance. Except when specifically authorized, firearms are forbidden at MWV facilities.
II. Integrity
Integrity is fundamental. We will conduct our business fairly and honestly at all times and must avoid any action that might call into question the reputation of our company or its employees.
Gifts and Entertainment
No gift or entertainment may be given or accepted that would affect the business judgment of the recipient or influence a business decision.
It is common business courtesy to pay for or to accept ordinary and occasional business meals and entertainment. Indeed, appropriate accommodations of this kind properly foster business relationships based on friendship and trust.
When exchanges go beyond common business courtesy in frequency, kind or value, however, employees must review the situation with their supervisor.
Employees may not provide, directly or indirectly, any payment, gift or entertainment to a government official. While modest courtesies may be lawful and appropriate under exceptional circumstances, any practice of providing such courtesies must be reviewed in advance with the Law Department.
Conflicts of Interest
MWV policy prohibits any action taken for an employee's own benefit, or for friends or family, that has the potential to interfere with the interests of the company. Similarly, business opportunities that employees identify through their position as an employee belong to the company and may not be used for personal gain.
A conflict of interest can arise in any number of situations, for example:
competing against MWV;
investing in companies doing business or competing with MWV;
maintaining other employment or a business that adversely affects job performance at MWV;
doing business on behalf of MWV with a company that employs a relative;
using MWV property, information or position for personal gain.
Employees must fully disclose any potential conflict of interest to their supervisor, to senior management or to the Law Department.
Political Participation
MWV encourages participation in political activity, including appointment or election to public office. Employees seeking public office, however, must obtain the approval of a supervisor and the Corporate Affairs Department.
Subject to limited exceptions, employees may not use any funds or assets of the company, directly or indirectly, to assist any candidate for public office or for any political parties or committees.
No MWV employee may engage in any lobbying activity without the prior approval of the Corporate Affairs Department.
Antitrust and Fair Dealing
We must always seek to deal fairly with our customers, suppliers, competitors, employees and others. Employees may not take advantage of anyone through illegal conduct, deceit or any other unfair practice.
Employees may not provide any competitor with information about our prices or about internal matters affecting our prices. It is illegal to enter into any agreement with a competitor concerning prices, costs, terms, customers, markets, production, business plans or any other matter that could affect competition. Keep in mind that an unspoken agreement to fix prices or allocate markets is just as illegal as a spoken or written agreement.
This is a complex area. Affected employees are expected to be familiar with the company's antitrust policy and consult with the Law Department as appropriate.
Record Creation and Retention
MWV's books, records and reports must be complete and accurate. If an employee becomes aware of any failure to follow this policy, they must report it to their supervisor and to the Law or Audit Departments.
Employees should avoid the creation of inappropriate documents that include exaggeration, derogatory remarks, legal conclusions or other statements that might prove to be misunderstood or wrong when examined in the course of an audit or a regulatory or legal proceeding.
Employees should be aware that email, voicemail and other communications stored on MWV equipment belong to the company. These communications may be retrieved and disclosed by the company as necessary and appropriate for business and legal purposes.
Records must be retained, discarded or destroyed in accordance with applicable laws, regulations and company policy. Records relevant to an investigation or to litigation must be retained.
Securities Transactions
It is illegal to buy or sell the securities of any publicly traded company, including MWV, while in possession of material nonpublic information about that company. Similarly, employees may not give such information to another person who might trade in the securities or who might pass the information on to others.
Company Assets
Employees have a duty to safeguard MWV's property, including proprietary and confidential information. Company property may be used only in connection with company business. Proprietary and confidential information to be protected includes technical and scientific information, as well as information about products, operations, personnel, marketing plans, supplier arrangements, pricing information and other data that we use in conducting our business.
An employee's obligation to protect this information continues after they leave MWV.
III. Respect for the Individual
MWV is committed to developing and maintaining a diverse workforce. Unlawful discrimination in the hiring, promotion, compensation or retention of employees is strictly forbidden.
Abusive, harassing or offending conduct is unacceptable, whether verbal or physical. Examples include unwelcome sexual advances and derogatory ethnic or racial comments.
Retaliation against employees for lodging a good faith complaint about discrimination or harassment will not be tolerated.
IV. Environmental Stewardship
MWV takes pride in its environmental leadership and responsible stewardship of natural resources. The company is dedicated, not only to full compliance with all environmental laws, regulations and permits, but also to careful protection of our environment.
MWV has instituted detailed programs designed to safeguard the environment. It is critical to the effectiveness of these programs that employees follow all of the procedures that apply to their facility, including record-keeping and reporting requirements.
Employees must immediately report suspected environmental problems, including spills and malfunctions of environmental control equipment, to an appropriate manager. Managers must take appropriate remedial action and ensure that timely notification is made to government agencies as required by law.
V. How to Report Violations or Get Help
The company has established several places to go for further help or to report a violation of this code or of company policy. Employees should never hesitate to seek help. Employees must report any violation that they identify.
An employee's supervisor or location manager can provide guidance, or they can contact a human resources representative or the Law Department. Additionally, the MWV Compliance Policy manual describes the company's policies and requirements in further detail.
Employees may also call the MWV Ethics Line at +1 (800) 457-6435 for assistance or to report a violation. Employees may remain anonymous. Alternatively, employees may email concerns to ethics@mwv.com and may also write to the MWV Ethics Line at:
MWV Ethics Line
One High Ridge Park
Stamford, Connecticut 06905, USA
All communications will be investigated as appropriate and kept as confidential as possible. No employee acting in good faith will be subject to discipline for providing information concerning suspected violations of law or company policy.
The MWV Board of Directors strongly discourages any waivers of this code. Any request for a waiver will be reviewed by the board and will be disclosed as required to shareholders.
VI. Conclusion
Safety. Integrity. Respect for the individual. Environmental stewardship. These principles shape every action we take as MWV employees around the world.
Every employee has the responsibility to safeguard MWV's good name and has a personal obligation to adhere to this Code of Conduct, to company compliance policies and to all laws and regulations. Where company policy is more restrictive than local law or practice, employees are to follow company policy.
Any failure to follow our compliance policies may result in discipline, including termination. Unwavering adherence to the highest ethical standards is crucial to our success. It is the right course of action wherever we do business.
