CA Supply Chain Transparency

California Transparency in Supply Chains Act Disclosure Statement

Last updated: March 14, 2025

Liberty Carton Co. d/b/a Liberty Packaging, Liberty Carton Co.-Texas d/b/a Liberty Packaging, Service Container Company, LLC d/b/a Liberty Packaging, Omaha Box Company d/b/a Liberty Packaging, and Miller Container Corporation d/b/a Liberty Packaging (collectively, “Liberty Packaging,” “we,” or “us”) is committed to complying with all laws and meeting or exceeding regulations wherever we conduct business.

Internal Accountability

Liberty Packaging’s Code of Conduct outlines Liberty Packaging’s policy related to labor law compliance and human rights. It is Liberty Packaging’s policy not to do business with suppliers or others that do not comply with applicable labor laws or support human rights. Liberty Packaging respects and supports human rights and individual freedoms. Goods or services that have been manufactured or provided in violation of applicable labor law or human rights will not be purchased or used by Liberty Packaging. Liberty Packaging does not tolerate abuses such as child labor, human trafficking, slavery, and forced labor.

All Liberty Packaging employees are bound by the Code of Conduct. Contract workers, consultants, agents, and representatives are required to observe the same standards of conduct as Liberty Packaging employees when conducting business for Liberty Packaging. Violations of the Code of Conduct may lead to serious sanctions, including fines, prison terms, and termination of employment for cause.

Liberty Packaging encourages the reporting of potential violations of the Code of Conduct. Reporting avenues are outlined in the Code of Conduct, including an online and toll-free telephone Ethics Hotline, both managed by an independent third-party company for anonymous reports. The Ethics Hotline is available 24 hours per day, 7 days a week, and the third-party provider can accommodate multiple languages. Additionally, retaliation against any employee who makes a report in good faith is strictly prohibited.

Verification

While Liberty Packaging does not have a formal process to verify the risks of human trafficking and slavery within our global supply chain, we are cognizant of the geographic regions of the world where such risks are elevated. Liberty Packaging has begun to develop processes, including evaluation of product supply chains, to address the risks of slavery and human trafficking. Liberty Packaging does not use a third-party monitor to conduct verification activities at this time.

Audits

Liberty Packaging does not currently conduct any specific audits to assess compliance in regards to the prohibition of slavery and human trafficking. Liberty Packaging has begun to develop processes, including evaluation of product supply chains, to address the risks of slavery and human trafficking.

Certification

Liberty Packaging’s Standard Purchase Terms and Conditions explicitly require that the seller warrants that all materials were manufactured, produced, furnished and delivered to Liberty Packaging in full and complete compliance with all applicable laws and regulations. Currently, Liberty Packaging does not require direct suppliers to specifically certify that they comply with anti-slavery and human trafficking laws in the country or countries in which they do business.

Training

All Liberty Packaging employees are required to take Code of Conduct training periodically. Liberty Packaging also conducts training on specific compliance topics on a quarterly basis for employees with regular computer access. Liberty Packaging does not currently provide employees or contractors with regular training on human trafficking and slavery.