Our Code of Business Conduct and Ethics is reviewed regularly by our
Board of Directors, management and outside counsel to consider
evolving issues and best practices. Final decisions on changes to
the Code must be approved by the Board of Directors.
In addition, each year, our salaried personnel certify their
personal compliance with the Code. Our proactive compliance training
program includes live and online Code training in numerous contexts
for employees of all levels. Approximately 8,500 employees, or over
25% of our workforce, including all our senior executives and middle
management, received online Code training in 2018 to supplement our
in-person training programs.
We offer several ways for employees and other stakeholders to report
concerns about suspected unethical behavior safely, promptly and
Speak directly to their supervisor or plant manager (or
Call the Crown Compliance Office using the 24/7 toll-free
reporting hotline (800-523-3644).
Contact their local Compliance Officer (see list available on the
We handle all inquiries promptly and investigate to the fullest
extent necessary. Violations of the Code of Business Conduct and
Ethics are subject to disciplinary action up to and including
termination of employment. Any employee who reports a violation will
be treated with dignity and respect and will not be subjected to any
form of discipline or retaliation for reports made in good faith.
Senior management regularly reports to the Audit Committee of the
Board of Directors on the status of open Code matters.
No Crown employee, officer, director or independent third party
acting on behalf of the Company may pay, offer or promise to pay, or
authorize payment to any party, public or private, in any country,
in order to secure an improper benefit for the Company, to cause the
party to act contrary to their duties or, in the case of a
government official, to influence that government official to obtain
or retain business or an advantage in the conduct of business. Nor
may they accept or solicit such payments or advantages. "Payment"
includes making bribes or kickbacks, as well as conferring anything
of value or any advantage, whether tangible or intangible (e.g.,
gifts, entertainment, travel expenses, charitable donations,
political contributions, hiring an individual or relative).
Management undertook a risk analysis of 100% of Company operations
and their susceptibility to corruption. Based on those findings, we
identified the personnel within those operations who might face a
greater possibility of exposure to corruption based on their job
functions and levels. Each of these individuals receives
comprehensive training, including in-person education sessions every
few years. We supplement the in-person sessions with regular
mandatory online courses assigned to 100% of our salaried staff.