Whistleblowing and Business Ethics Hotline Policy

Purpose

Թ51 Holdings, Inc. and its subsidiary companies (collectively “Թ51”) are committed to maintaining its values and operating in accordance with the highest ethical standards. To fulfill this commitment, Թ51 depends upon every director, officer, and employee to conduct business with integrity; to respect and obey all applicable laws, rules, and regulations; and to strive to adhere to the highest standards of honesty, morality, and decency in the performance of his or her job responsibilities.

In furtherance of this commitment and Թ51’s commitment to fostering an environment where concerns can be raised and issues addressed without fear of retaliation, Թ51 is implementing this stand-alone Whistleblowing Policy together with Թ51’s new Business Ethics Line (“CBE Line”).  The CBE Line serves as a confidential channel, administered by a third party, for employees, directors, officers, consultants, customers, vendors and business associates to report in good faith potential violations of Թ51’s Code of Business Conduct and Ethics or any other applicable Թ51 policy or legal requirement.

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Whistleblowing Policy

Every employee bears the responsibility to protect Թ51’s reputation and integrity. If you know or believe that, in the conduct of business for or on behalf of Թ51, someone has violated applicable law, Թ51’s Code of Business Conduct and Ethics or any other applicable policy or legal requirement, it is important that you report the violation. Թ51 employees may report any such violations to (i) their supervisors, (ii) their plant managers or equivalent, (iii) the relevant regional Compliance Officer or (iv) the CBE Line which is administered by an independent third-party provider, Lighthouse Services.  Complaints about workplace issues or disputes such as grievances regarding performance evaluations, hours of work, wages, raises, disagreements with peers or supervisor, etc., are often best addressed to the relevant Human Resources personnel.

While each employee should report possible violations in the manner with which s/he is most comfortable, employees are strongly encouraged to report any concerns to their supervisors first.  If any employee feels hesitant in any way about reporting such a violation to his or her supervisor (for example, if the supervisor is personally involved in the violation), s/he may report the violation to the plant manager, the relevant regional Compliance Officer, the CBE Line or, in the case of interpersonal or employment issues, to the relevant Human Resources personnel. Subject to applicable law, reports will remain anonymous upon request. Because it is sometimes more difficult for the Company to investigate reports that are made anonymously, individuals are encouraged to report their concerns directly to their supervisors or plant managers or to share their identities when contacting the CBE Line, assuming they feel it is safe to do so. External business associates, such as Թ51 suppliers, sub-contractors or customers, may also report violations to the CBE Line.

Anyone who makes a report in good faith is protected by the section of this Policy below on anti-retaliation.

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Scope

This Policy is intended to encourage Թ51 employees, directors, officers, consultants, customers, vendors, sub-contractors and business associates to report, pursuant to the procedures set forth below, when they believe in good faith that unethical or illegal behavior, such as a violation of Թ51’s Code of Business Conduct and Ethics (“Code”), Թ51’s Supplier Code of Conduct, Թ51’s Human Rights Policy or Թ51’s Anti-Corruption Policy (collectively “Թ51’s Compliance Codes”), the law, or any other applicable legal requirement or policy, has occurred.¹ For purposes of this Policy, unethical or illegal behavior includes, without limitation:

  • Bribes, kickbacks or facilitation payments
  • Improper financial reporting, fraud, money laundering, or embezzlement
  • Anti-competitive practices such as agreements with competitors regarding pricing strategies or bids
  • Illegal insider trading
  • Falsification of company records
  • Concerns about accounting/auditing practices or the accuracy of financial statements or auditing matters
  • Excessive gift(s) from a vendor, partner, or customer
  • Harassment of or discrimination against an employee 
  • Theft of Թ51 assets for personal benefit
  • Purchase of personal items with company funds
  • Serious health and safety violations, including environmental concerns

A report is made “in good faith” when an individual has a sincere belief that the facts reported are true at the time of reporting and that a policy violation or unlawful conduct may have occurred. Reports that are made maliciously, or in bad faith, are themselves violations of Թ51’s Compliance Codes and may result in disciplinary action, up to and including termination of employment or business relationships.

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Procedure

Generally, Թ51 employees should first report any concern they may have regarding possible violations of Թ51’s Compliance Codes, the law, or other applicable policy or legal requirement to their supervisors. The supervisor is usually in the best position to answer any questions and offer guidance. If you feel hesitant in any way about reporting a possible violation to your supervisor, you may report your concern to the HR manager (for interpersonal or employment issues), plant manager or the relevant regional Compliance Officer. If you do not feel comfortable raising your concerns through Թ51’s traditional reporting channels, you may contact Թ51’s CBE Line.

The CBE Line is supported by a third-party vendor, Lighthouse Services, and staffed by trained professionals 24 hours a day, 7 days a week. To access the CBE Line, follow the instructions below:

  • Website:
  • English speaking USA and Canada: (877) 222-3029 (not available from Mexico)
  • Spanish speaking USA and Canada: (800) 216-1288 (not available from Mexico)
  • French speaking Canada: (855) 725-0002
  • Mexico: 800-681-5340
  • Outside of North America: 
  1. Make sure you have an outside line.
  2. Enter the for the country and/or the telephone system you are calling from. (See table below. Note Access Codes are subject to change - see ). 
  3. When prompted, enter the toll-free number (800) 603-2869. There is no need to dial “1” before the toll-free number.
  4. You are now connected to the CBE Line. A Lighthouse greeting will be played in multiple languages. Make a choice from the prompts or press 0 and tell the English operator the language you speak. An interpreter will then join the call.

Ethics Hotline Access Codes

Barbados: 1-800-225-5288   
Belgium: 0-800-100-10   
Brazil: 0-800-890-0288   
Brazil: 0-800-888-8288   
Cambodia: 1-800-881-001   
China (South, Shanghai - CT): 10-811   
China (North, Beijing CNCG): 108-888   
Colombia: 01-800-911-0010   
Columbia (Spanish): 01-800-911-0011   
France (Orange): 0-800-99-0011   
France (Telecom Development): 0-805-701-288   
Germany: 0-800-225-5288
Greece: 00-800-1311   
Hong Kong (Hong Kong Telephone): 800-96-1111   
Hong Kong (New World Telephone): 800-93-2266   
Hungary: 06-800-011-11   
Indonesia: 001-801-10   
Italy: 800-172-444   
Jamaica: 1-800-872-2881
Jordan: 1-880-0000
Malaysia: 1-800-80-0011
Myanmar*
Poland: 0-0-800-111-1111
Saudi Arabia*
Singapore (SingTel): 800-011-1111
Singapore (StarHub): 800-001-0001
Slovakia: 0-800-000-101
Spain: 900-99-0011
Switzerland: 0-800-890011
Thailand: 1-800-0001-33
Tunisia*
Turkey: 0-811-288-0001
United Arab Emirates: 8000-021
United Arab Emirates (du): 8000-555-66
United Arab Emirates (Military-USO & Cellular): 8000-061
United Kingdom: 0-800-89-0011
Vietnam (VNPT): 1-201-0288
Vietnam (Viettel): 1-228-0288

* Reporting by phone is not currently available for this location. Please use the online reporting option to submit a concern.

  • E-mail: reports@lighthouse-services.com (NOTE: you must include Թ51’s name with your report)
  • Mail: Lighthouse Services, 1710 Walton Road, Blue Bell, PA 19422 USA (NOTE: you must include Թ51’s name with your report)

Concerns expressed anonymously will be investigated, with consideration given to the seriousness of the issue raised, the credibility of the concern, and the likelihood of confirming the allegation from attributable sources. 

Reporters are encouraged to provide as much specific information as possible, including names, dates, places and events that took place; the general nature of the concern; and how the reporter became aware of the issue. Reporters are also encouraged to provide all supporting documents or references that they believe will enable Թ51 to make a proper assessment of the complaint.

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Investigations

Initial Receipt of Report

All reports to the CBE Line will be acknowledged as promptly as possible (usually within 7 days depending on the jurisdiction).  An acknowledgement of receipt of the report does not constitute notification that the allegations in the report are within the scope of this Policy or will be formally investigated. Additional information may be requested in the acknowledgement of receipt if the information provided by the reporter is incomplete or insufficient for Թ51 to properly assess the validity or scope of the concern. If Թ51 cannot provide an acknowledgement of receipt due to the lack of accurate contact information in the report, the reporter may obtain follow-up information regarding his or her concern by contacting the CBE Line. 

Թ51’s Legal Department will receive a copy of each report lodged with the CBE Line.  The Legal Department will assign the report to the appropriate departments (e.g., Human Resources, Finance, Internal Audit, Legal) to determine whether the reported concern is within the scope of this Policy and whether a formal investigation is needed. The action taken will depend on the nature of the concern (whether the type of complaint is covered by this Policy) as well as the level of information provided. Reports will only be shared with employees and third parties involved in the investigation. Anyone involved in the investigation who receives the report will be subject to confidentiality obligations. Note that some concerns may be resolved by agreed upon action without the need for a formal investigation.

A determination as to whether a reported concern falls within the scope of this Policy and whether an investigation is necessary will be made as promptly as possible and in accordance with all applicable laws and regulations. In the event it is determined that the reported concern does not fall within the scope of this Policy, the reporter will be notified and any personal data collected by the CBE Line from the reporter will be destroyed or anonymized where required by applicable law. 

Investigation of Reports Within Scope of Policy

If it is determined that a reported concern is within the scope of this Policy and an investigation is necessary, the assigned departments (e.g., Human Resources, Finance, Internal Audit, Legal) will initiate the investigation.  The manner of the investigation will vary depending on the nature of the reported concern. If a report does not include all relevant facts, and additional facts cannot be obtained by the investigators after reasonable efforts, there may be insufficient information to fully investigate the concern. Any person who has access to information during the course of an investigation, including third parties investigating on behalf of Թ51, is bound by a strict obligation of confidentiality. Any investigation will be conducted in a neutral and objective manner and will comply with all applicable local laws and regulations. The time required to complete an investigation will vary depending upon the type of conduct alleged and the availability of information related to it. To the extent the investigators deem appropriate, and in accordance with all applicable local laws and regulations, the reporter will be advised of the progress of the investigation and will receive feedback.  

Upon completion of the investigation, and as permitted by applicable law, corrective actions may be taken by Թ51 and/or disciplinary action may be taken against the subject of the report. The specific actions taken by Թ51 will vary with the matter at hand and the results of any investigation. Թ51 will endeavor to notify the reporter that the investigation has been completed and that appropriate measures, if any, have been taken.  All employees are expected to fully cooperate with any investigation performed by or on behalf of Թ51. 

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Anti-Retaliation

Թ51 will not tolerate retaliation or any retribution against anyone who, in good faith, reports a violation of Թ51’s Compliance Codes, or who participates in the investigation of such a report, even if sufficient evidence is not found to substantiate the concern. Anyone who reports, proposes to report or seeks advice concerning a possible violation will be treated with dignity and respect. Employees will not be subjected to any form of discipline or retaliation for reports made in good faith. Any Թ51 personnel found to have retaliated against or in any way punished a Թ51 employee for having in good faith reported a violation will be subject to discipline, up to and including termination. Abuse of the CBE Line or reports made maliciously or in bad faith are a violation of Թ51’s Compliance Codes and may result in disciplinary action, including termination of employment or business relationships. 

Additional protection measures may be provided in local jurisdictions depending on applicable laws.

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Confidentiality

Unless an individual is located in a country that restricts anonymous reporting, the CBE Line permits individuals to report concerns anonymously, at their discretion. Independent trained personnel, who are not Թ51 employees, administer the hotline. When a reporter requests anonymity, every effort will be made by the administrators of the CBE Line to protect the reporter’s identity. Please note that any information provided in a whistleblower report may be the basis of an internal and/or external investigation by Թ51 into the matter being reported. 

If a reporter provides his or her identity, or the reporter’s identity becomes known to Թ51, the Company will take all reasonable measures to keep the reporter’s identity confidential. Information relating to a reported concern is only communicated to the extent necessary. Any authorized individuals who have access to such information, including third parties involved in any investigation, will keep the identity of the reporter and any information related to the reported concern confidential. Any personal data collected as part of any investigation will only be retained until the conclusion of the proceedings, where required by applicable law.

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Last Revised: August 2024

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¹ In the event the potential concern relates to Թ51’s Transit Packaging Division (Signode), please contact Signode’s Confidential Hotline at .

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