Corporate Ethics

Overview

For well over 100 years the activities of our company, and its place in the Australian community, have been characterised by a genuine respect for the laws of the land, respect for the rights of individuals and high standards of ethical behaviour.

As Amcor expands in Australia and overseas, it is important that we continue to meet our fundamental responsibilities to act ethically in all dealings with our shareholders, suppliers, customers, advisers and regulators, competitors, fellow employees and the communities in which we work.

Amcor's Statement on Corporate Ethics summarises the company's policy on corporate behaviour as a guide for management and employees of the company and for the information of those who have an interest in the way we conduct our businesses.

Statement on Corporate Ethics

Amcor's policy is that the affairs of the company and its subsidiaries are conducted, at all times, in accordance with all applicable laws and regulations in the countries in which we operate, and, as well, in accordance with high ethical standards. All directors, senior executives and other employees are expected to act lawfully, in a professional manner and with the utmost integrity in their dealings with our shareholders, customers, suppliers, advisers and regulators, competitors, the community and each other, striving at all times to enhance the reputation and performance of the Group.

1. Ethical Conduct Generally

All Amcor personnel should understand that ethical conduct is a fundamental part of their duty to our shareholders, customers, suppliers, advisers and regulators, competitors, the community and fellow employees.

Ethical behaviour in business, personal and community conduct, extends beyond the duties imposed by laws or regulations and clearly includes:

• Honesty and loyalty in dealings with the company and fellow employees
• Scrupulous avoidance of deceptive or "sharp" practices or dishonourable conduct which would reflect unfavourably on Amcor; avoidance of the temptation to pursue personal gain or advantage in conflict with the interests of the company
• Striving to exercise sound business judgement, while providing the highest possible standard of service to our customers
• The proper use of the company's resources and information.

By strict compliance with local laws and regulations and observance of these principles we will demonstrate that we are aware of our responsibilities as a corporate citizen in whatever country we operate.

2. Dealing in Shares of Amcor Limited

In the course of their employment with Amcor, some people will possess privileged price-sensitive information about the company. The Australian Corporations Law inter alia imposes particular duties on such people and prescribes criminal penalties for breaches of these obligations.

Persons who have such 'inside information' (that is information about the company which the person obtained directly or indirectly from the company which has not been broadly disclosed to the general public and which could, if known, affect a shareholder's decision to buy, sell or hold Amcor shares) should not buy or sell the Company's shares other than:

• In the period between the announcement of the full year result and fourteen days after the annual general meeting.
  
• In the period of fourteen days following the announcement of the half year result.

Even at these times there could be occasions when it is not proper for these employees, because of their knowledge, to buy or sell Amcor shares. If in doubt, those concerned should seek the prior approval of the Company Secretary, Executive General Manager Finance or Managing Director as appropriate.

3. Trade Practices Policy

Sound business practice requires the company and its employees to compete fairly, honestly, and lawfully with its competitors.

In most countries in which Amcor operates, there are consumer protection and anti-monopoly legislative provisions to be observed. Amcor's policy is to comply with these laws.

In Australia, the Trade Practices Act 1974, now administered by the Australian Competition and Consumer Commission, sets consumer protection standards and prohibits certain practices which are considered to be anti-competitive.

Amcor's policy is to ensure that all relevant employees are made aware of these provisions, and of the need to comply with them, by an education program which includes the distribution of compliance manuals and by the explanation and elaboration of these requirements by independent experts on a regular basis. This Australian procedure is adapted as appropriate for other countries in which Amcor operates.

4. Environmental Policy

Amcor believes that environmental management is among the highest corporate priorities and environmental responsibility is accepted as an integral part of the company's operations.

Amcor is committed to reduction of waste at source, recycling and other responsible methods of waste management and to fully comply with all related legislation and regulation.

Amcor will ensure that its employees are:

• well informed about relevant environmental issues
• familiar with and conform to group environmental policy
• free to communicate their concerns about policy and performance to responsible management.

5. Occupational, Health and Safety Policy

Amcor is committed to maintain and provide as far as practicable, a safe and healthy working environment conducive to job satisfaction and productivity.

The company will fully comply with all relevant occupational health and safety laws and regulations and is committed to ensure that everything practical is done to prevent injury from unsafe practices, machinery or harmful elements in the working environment.

To ensure the successful implementation of this policy employees are to comply with workplace safety policies and are encouraged to actively participate in ensuring the safety of their workplace.

6. Employee Related Issues

Amcor believes that its people are an important asset and is committed:

• To ensure that any agreements with employees are adhered to.
• To ensure that employees receive fair and competitive remuneration and advancement based on abilities, performance, skills and qualifications.
• To provide the training and development necessary to realise mutually beneficial individual and company goals.

Amcor's policy is to comply fully with all relevant legislation and support the principle of equal employment opportunity to all employees regardless of race, colour, nationality, religion, sex, age, disability or marital status.

As individuals and as a member of the Amcor group, we should be aware of, and seek to eliminate, any barriers that may interfere with the achievement of this policy.