Our Commitment

Bemis is and will remain: (1) a valued supplier of quality products to our customers; (2) an employer providing a challenging and satisfying occupational experience for our employees; (3) a rewarding investment for our shareholders; and (4) a responsible citizen of the communities where we are located.

To uphold this Commitment it is essential that each and every Bemis employee protect our most important asset… Bemis’ reputation for integrity. In our code of ethics, all employees, officers and directors are referred to as “employees.”

Integrity and the highest ethical standards go hand-in-hand. Bemis’ outstanding reputation is built on the actions of its thousands of employees starting before the American Civil War. Future success depends, in large part, on the continued good judgment of all employees. Below is a list of suggestions as to how to continue to “do the right thing.” It is not a list of “don’ts.” If a question or situation appears particularly difficult, employees are encouraged to contact their supervisor or the Bemis General Counsel’s office.

If all of us make this Commitment, Bemis will continue to be a successful company.

Employment

Bemis is committed to hiring and promoting employees fairly, based on talent and merit. All employees are entitled to respect; to be evaluated and promoted based on their contribution; and to work free from harassment. Bemis and its employees will strive to achieve and maintain this positive work environment. Our goal is to attract and retain a diverse workforce that closely matches the diversity of the communities in which we work.

Antitrust

Bemis competes aggressively and legitimately, in full compliance with all antitrust laws. Antitrust laws are designed to protect competition, and Bemis expects all of its employees to adhere to these laws. Antitrust laws require that there be no agreements or understandings between competitors that affect price, terms and conditions of sale, division of markets, or any other agreements or understandings that would affect competition. Bemis employees should never have any discussions with competitors regarding price or any other aspect of competition. It is a felony to violate antitrust laws, and punishment can result in imprisonment and fines. Violation of antitrust laws can also have a devastating impact to both the Company’s and the employee’s business reputation.

Insider Trading

Bemis policy, in addition to federal and state securities laws, prohibits employees from buying or selling Bemis shares if they are in possession of material, nonpublic information. Employees are also prohibited from disclosing such information to anyone outside the Company until the information has been publicly disclosed and the securities markets have had an adequate opportunity to consider it. Material information is any information that an investor might consider important in deciding whether to buy, sell or hold securities. Such information could include financial results, forecasts, acquisitions, divestitures, product developments, changes in management and changes in auditors.

Drugs and Alcohol

Bemis is committed to providing a work environment free of illegal drugs and alcohol. Substance abuse poses health and safety risks both to the abuser and to his or her fellow employees. Our policies are designed to eliminate substance abuse, not the abuser.

Conflict of Interest

Involvement in any business or activity which conflicts with, or gives the appearance of conflicting with, the business activities of Bemis or which misuses Bemis’ resources, good name or reputation may affect an employee’s commitment to Bemis. If in doubt, check with the appropriate supervisory person.

Confidential Information

Confidential information includes trade secrets, customer lists, pricing data, process information and financial reports. Disclosing or “leaking” confidential information may assist a Bemis competitor or violate Federal or State Securities Laws.

Compliance with Laws and Regulations

It is Bemis’ policy to comply with the letter and the spirit of the laws and regulations of the countries in which we operate. It is each employee’s responsibility to be certain Bemis is acting legally as to those activities for which they are responsible.

Political Contributions

The laws governing political contributions vary from state to state, but in general are very strict and carry serious penalties. Accordingly, Bemis will not make political contributions, reimburse employees for doing so or authorize employees to be solicited for contributions except in unusual circumstances and after careful management and legal review.

Internet and Communications System Usage

Access to the Internet and use of all e-mail and voicemail systems are to be used by Bemis employees for legitimate business use and incidental personal use at reasonable levels. All electronic systems are the property of Bemis and there is no right to privacy in any material created, received or sent on the Bemis systems. Access to the Internet is provided on an as-needed basis and requires appropriate approval. Access to the Internet via modem or any networked company computer, other than through the Bemis-provided Internet gateways, is prohibited. Bemis reserves the right to monitor Internet and e-mail usage and filter or block objectionable content. The origination or communication of offensive, hostile, malicious, unlawful or abusive material, not in keeping with Bemis Company values, is prohibited. Only Bemis standard hardware and software will be supported, and Bemis reserves the right to remove any software or hardware that is not appropriately licensed, supported or that disrupts network/system performance. All personal computers which are connected to the Bemis network will employ Bemis standard virus protection software.

Social Media

Employees’ participation in blogs and social computing are subject to the same principles and guidelines that apply to employees’ activities in general as found in our code of ethics. Social computing activities include but are not limited to online publishing and discussion, wikis, file-sharing, user-generated video and audio, and social networks. Employees are expected to exercise personal responsibility and follow company policies on anti-harassment, ethics, and confidential and proprietary company information regardless of location (i.e. at work on a company computer or on personal time with a home computer.)

Gifts and Entertainment

Gifts and entertainment of nominal value that are part of the normal business process are acceptable. Any gift, or offer of entertainment which could, however, be interpreted as an attempt to influence business judgment, should be rejected. A cash gift of any amount from a supplier, client or other business associate is never acceptable.

Workplace Violence

Bemis is committed to providing a safe work environment for all of its employees. Bemis Company prohibits the possession of any weapon on Company property unless such prohibition is specifically disallowed by law. This prohibition includes, but is not limited to, all firearms, knives and/or any weapon whether used for hunting, protection, or any other purpose and extends to all Company property including its parking lots. Employees who violate this policy against weapon possession on Company premises can be subject to discipline, up to and including discharge.

International Business and Foreign Corrupt Practices Act

The United States laws governing International Trade Controls, including boycotts and the Foreign Corrupt Practices Act, are very complex. Bemis will attempt to comply with all such laws. Bemis policy forbids bribery in the United States and abroad, and the Foreign Corrupt Practices Act prohibits the making or offering of any payment to any foreign official for the purpose of obtaining, retaining or directing business. Any person involved in international transactions should maintain a basic awareness of applicable laws and regulations. Employees should watch for “red flags” and contact the General Counsel’s office or the international tax department for general guidelines or advice on particular items of concern.

Company Overview