Doing business the right way

Code of Conduct

We are committed to always doing business the right way. We operate with the highest standards of integrity and honesty and comply with all applicable laws and regulations in all dealings within our business, with others (including customers, suppliers and public authorities), and with the communities in which we operate. Our Code of Conduct sets out our commitments, and our expectations for employees and business partners on how to do business the right way.

Preventing bribery and corruption

We do not tolerate any forms of bribery or corruption and we comply with all applicable anti-bribery and corruption laws. We have set out our position clearly within our Code of Conduct and we have also implemented various policies and guidelines including our Anti-Bribery and Corruption Policy. Ardagh is a signatory of the United Nations Global Compact (UNGC) and is committed to working in alignment with the UNGC’s principles, including that it is against corruption in all its forms.

How we manage compliance

Our Code of Conduct sets out the commitment to acting with integrity and is supported by a compliance framework to ensure that we appropriately manage compliance within our business. Our Chair and CEO set a clear tone from the top to ensure colleagues are clear about the importance of acting with integrity and adhering to our Code of Conduct.

The Board has entrusted the Audit Committee with the oversight of the compliance function and of our risk management. On the compliance side, the Audit Committee has established a Compliance Committee which drives the implementation of our Code of Conduct and ensures that appropriate policies are in place to address Ardagh’s compliance risks. The Compliance Committee is also responsible for reviewing compliance violations and reporting these to the Audit Committee. The Compliance Committee includes representatives from across Ardagh’s operating businesses.

In addition to robust governance structures, strong leadership and a clear direction from leadership, compliance issues are reviewed as part of our overall risk management system. Through this we identify and assess our compliance risks, implementing mitigation measures where necessary. We provide employees with training on our Code of Conduct and various key risk areas, including anti-bribery and corruption and competition compliance.