Business Ethics

Operating Responsibly

We know that to operate successfully, we must have the trust of all our stakeholders. That includes our employees, customers, shareholders, partners and suppliers, the governmental and nongovernmental organizations we work with and the communities where we conduct business.

We earn that trust by doing what is right and ethical. We comply with applicable legal, regulatory and industry code requirements and uphold the highest principles of integrity and standards in every aspect of our business and every market in which we operate. That mindset is ingrained into our business culture and is monitored, enforced and improved through our globally deployed Code of Business Conduct and Ethics. Available in 14 languages, the code outlines the high level of ethical behavior expected from our directors, officers and employees.

We supplement our Code of Business Conduct and Ethics with standalone policies for certain issues covered by the Code, such as Antitrust Law Compliance, Anti-Corruption Law Compliance, Trade Sanctions Law Compliance, Related Party Transactions and Environment, Health and Safety Compliance.

Ethics Management

Our Code of Business Conduct and Ethics is reviewed regularly by our Board of Directors, management and outside counsel to consider evolving issues and best practices. Final decisions on changes to the Code must be approved by the Board of Directors.

In addition, each year, our salaried personnel certify their personal compliance with the Code. Our proactive compliance training program includes live and online Code training in numerous contexts for employees of all levels. Approximately 8,500 employees, or over 25% of our workforce, including all our senior executives and middle management, received online Code training in 2018 to supplement our in-person training programs.

We offer several ways for employees and other stakeholders to report concerns about suspected unethical behavior safely, promptly and confidentially:

  • Speak directly to their supervisor or plant manager (or equivalent).
  • Call the Crown Compliance Office using the 24/7 toll-free reporting hotline (800-523-3644).
  • Contact their local Compliance Officer (see list available on the Corporate website).

We handle all inquiries promptly and investigate to the fullest extent necessary. Violations of the Code of Business Conduct and Ethics are subject to disciplinary action up to and including termination of employment. Any employee who reports a violation will be treated with dignity and respect and will not be subjected to any form of discipline or retaliation for reports made in good faith. Senior management regularly reports to the Audit Committee of the Board of Directors on the status of open Code matters.

Anti-Corruption Policies

No Crown employee, officer, director or independent third party acting on behalf of the Company may pay, offer or promise to pay, or authorize payment to any party, public or private, in any country, in order to secure an improper benefit for the Company, to cause the party to act contrary to their duties or, in the case of a government official, to influence that government official to obtain or retain business or an advantage in the conduct of business. Nor may they accept or solicit such payments or advantages. "Payment" includes making bribes or kickbacks, as well as conferring anything of value or any advantage, whether tangible or intangible (e.g., gifts, entertainment, travel expenses, charitable donations, political contributions, hiring an individual or relative).

Management undertook a risk analysis of 100% of Company operations and their susceptibility to corruption. Based on those findings, we identified the personnel within those operations who might face a greater possibility of exposure to corruption based on their job functions and levels. Each of these individuals receives comprehensive training, including in-person education sessions every few years. We supplement the in-person sessions with regular mandatory online courses assigned to 100% of our salaried staff.