We are committed to maintaining the trust of our stakeholders. An uncompromising commitment to integrity drives us to behave in a manner that demonstrates respect, transparency, accountability and leadership.

Transparency, Accountability and Leadership

All of our directors, officers and employees must adhere to ethical business practices and fully comply with our corporate policies and procedures, as well as applicable laws and regulations. We strive to at all times act with awareness of our responsibility as a corporate citizen and to protect the safety and health of one another, the environment and the communities in which we live and work. There is no acceptable excuse for not doing so.

We have adopted corporate policies and procedures, including those described below, that promote the effective functioning of our Company to maximize long-term shareholder value, reinforce Berry’s culture of accountability, ownership, communication, leadership and entrepreneurship, and ensure that our company is managed with integrity and in the best interest of our shareholders.

Achieving Success

We work hard to earn the trust of our stakeholders, and maintaining this trust is essential to Berry’s future success. Our core values at the forefront of everything we do to ensure that our decisions and actions advance the best interest of our shareholders. They reflect the Berry First principle and reinforce our commitment to managing our business with integrity and in keeping with the highest ethical standards, and we expect that commitment from all of our directors, officers, employees and business partners.

Our Corporate Code of Business Conduct and Ethics (also known as the “Code of Conduct”) helps us to do this. Our Code of Conduct provides important guidelines for our directors, officers, employees and business partners to ensure that we conduct our business legally and ethically. However, the Code of Conduct is only a guide. It is the ongoing duty and responsibility of every Berry director, officer and employee to live by our core values and protect the company’s reputation at all times and avoid any appearance of improper conduct. This means that we do the right thing even when no one is looking. We expect the same of our business partners.

On October 29, 2020, the Board adopted certain amendments to the Code of Conduct, effective immediately. The amended Code of Conduct emphasizes the Company’s commitment to the highest standards of integrity and ethical business conduct, and enhances and clarifies existing obligations under the Code, including those relating to diversity, inclusion and equity, non-discrimination, and human rights, as well as conflicts of interests and expectations of our business partners.

Suppliers and Business Partners

Suppliers and contractors play a vital role in Berry’s success and we rely heavily on them to help us conduct our business, live our values, and create value for our stockholders. We are committed to the highest ethical standards in selecting and working with our suppliers and contractors. We have adopted a Supplier Code of Conduct that outlines the expectations we have for the suppliers and contractors with whom we partner. The Supplier Code of Conduct provides the foundation for our procurement policies, guidelines and practices, as well as our ongoing evaluation of Berry’s suppliers and contractors and constitutes additional terms of your contract with Berry. We do not make compromises in these areas and we expect our suppliers and contractors to always adhere to the letter, spirit and intent of these expectations and values.

Board Diversity

We are committed to diversity at the Board level, and believe that good and responsible stewardship takes a top-down approach. The Berry board has committed to voluntarily comply with California laws supporting Boardroom diversity. Our commitment to diversity is also captured in our Corporate Governance Guidelines.

Stakeholder Engagement

Berry is committed to an environment where open, honest and direct communications are the expectation, not the exception. We understand that communication starts by listening, understanding different perspectives, and caring about the success and well-being of all stakeholders.

As part of our commitment to accountability and communication, we established a dedicated and direct communication channel to the Berry leadership team. Shareholders and other interested parties may communicate with our executive team or the Board (including the lead director, the chair of any committee, our the independent directors as a group) by emailing our General Counsel, who also serves as Corporate Sectary, at StakeholderEngagement@bry.com.

Public Policy Advocacy and Political Contributions

Berry proactively engages with the California executive and legislative branches and with regulatory agencies. We build relationships with legislators, regulators and other policymakers by communicating and demonstrating our commitment to state goals and policies in the simultaneous pursuit of our corporate goals. We engage in the legislative and rulemaking processes both directly and indirectly, through trade organizations. We support candidates and political organizations that share and advance our corporate interests. We do all of this ethically and in compliance with all federal, state and local laws, something we achieve by adherence to our policy on political engagement.

Ensuring Sustainable Operations

We measure ourselves against the highest standard of integrity and hold ourselves accountable. Berry offers a third-party managed, independent “hotline” service that is available 7 days a week, 24 hours a day. The information you provide will be sent on a completely confidential and anonymous basis, if you should choose. Reports can be submitted over the phone or online:

  • Dial toll-free, within the United States, Guam, Puerto Rico and Canada: 1-844-836-0245
  • https://secure.ethicspoint.com/domain/media/en/gui/51948/index.html
  • You have our guarantee that your comments will be heard.

    EthicsPoint is NOT a 911 or Emergency Service. Do not use this site to report events presenting an immediate threat to life or property. Reports submitted through this service may not receive an immediate response. If you require emergency assistance, please contact your local authorities.

    Committee Composition
    Audit Committee
    Compensation Committee
    Nominating and Corporate Governance Committee