Huh Q - P,Pl CODE OF ETHICS AND BEHAVIOUR POLICY

1. Introduction

At Huhtamaki-PPL Limited (HPPL) we bel ieve that we are trustees of all our stakeholders including the society in which we exist, shareholders, employees and their families, customers, suppliers, contractors, the Government, et al.. We believe that we owe it to all stakeholders to conduct our business in li ne w ith sound ethical standards.

This Code sets out the standards of ethical behavior required of all employees whenever they act on !Jehalf of HPPL or any of its subsidiaries (hereinafter referred either solely or jointly as the ·'Company").

The Code is designed to provide broad and clear guidelines to the minimum standards of conduct expected of every employee. The Code is not intended to be a summary of all HPPL policies or a list of rules that addresses every situation one might encounter. There is no substitute for good judgment, common sense and fair play.

HPPL is committed to complying with applicable laws and to work within the spirit of commonly accepted best practices. The Company will not condone any violation of the law, including any participation in illegal acts, or unethical business dealings by an employee.

2. Accountability

Every employee is responsible for his/her own actions. HPPL holds each employee, regardless of position or stahts, accountable for complying with the Code, HPPL po licies and the law. If an employee does not understand applicable laws or HPPL ' s expectation for his/her behaviour, the employee has the responsibility to ask his/her seniors(s).

Failure to live up to the standards set forth in this Code can result in an employee being held guilty of indiscipline, with a penalty up to and including termination of employment. Furthermore, since many provisions of this Code and HPPL policies are based on legal requirements, violations may result in prosecution under relevant laws.

3. Responsibilities of Seniors.

Seniors have the responsibility of creating and sustaining an open and ethical work environment. In the context of HPPL, a senior shall mean anyone with supervisory responsibilities over any other employee. Seniors are expected to lead by example. Seniors must communicate the Code and relevant HPPL policies to all of their direct reports and help them understand these requirements. Seniors must show respect towards employees and maintain open, honest and constructive two-way communication with them. This means not only allowing and encouraging employees to ask questions, but also making suggestions

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Huhtamaki - PP and reporting wrongdoings. Seniors must be vigilant to prevent violations of this Code, HPPL policies or the law. When allegations of wrongdoing are brought to their attention, seniors must investigate every such matter and then take corrective or disciplinary actions as necessary.

In case an employee is not satisfied with the effort of his/her senior to comply with this Code, the employee is expected to contact his/her senior' s senior, that is the next reporting level.

4. Working within Society

HPPL is acutely aware of its responsibilities towards the Society in which the company and its business operates. HPPL acts in all ways as a "good citizen" and acts towards the development of Society. HPPL has a separate detailed Policy on Corporate Social Responsibility to be followed in action and spirit.

5. Working with Customers arid Others Outside the Company

• Fair Dealing

HPPL deals fairly with customers, suppliers and competitors. HPPL does not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other unfair practices.

• Product Suitability and Safety

HPPL produces products in compliance with the specifications of its customers and strives to ensure that products supplied are made according to the relevant specifications and from safe and legally permissible raw materials and that strict quality standards and controls are followed.

• Dealing with Customers

At HPPL integrity is a given and not negotiable. It is essential to be honest with customers, treat them with respect and dignity and promise only what can be delivered. Satisfied customers are the key to HPPL's success. HPPL aims to earn customers' continued loyalty every day by treating them fairly, delivering the products and services they want and exceeding their expectations.

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uhta ki -P,PL • Marketing Practices

At HPPL our products and services are desc ri bed truthfully and accurately. Misleading customers through deceptive acts or practices, false advertising claims, misrepresentations regarding HPPL 's or competitors ' products and services or other unfair methods of competition are forbidden.

HPPL aims to compete fairly and honestly. Commercial Laws, Antitrust laws and competition regulations are to be complied with.

Communications and proposals, bid preparations and contract negotiations must always meet the highest standards of integrity and truthfulness.

• Confidentiality of Customer and Business Partner Information

The confidentiality and security of sensitive information of clients and business partners are kept secret as any other confidential information in the Company.

• Business Partners

HPPL shall avoid doing business with those who are likely to harm HPPL ' s reputation. All arrangements with third parties must comply with Company policies and the law.

• Supply Chain

HPPL expects its suppliers to follow similar ethical policies and principles as laid in the Code. Employees are expected to report to a senior any incident that raises a doubt about HPPL 's supplier' s proper conduct.

• Bribes and Improper Payments

HPPL does not pay or accept bribes or other similar payments to uphold or to contribute to its business.

Improper payments to anyone, for any reason are strictly forbidden. HPPL obtains business based on the merits of its products and services. "Improper payments" means not just payments of cash or currency but may include anything sufficiently valuable (trips, gifts, etc.) that may be construed as swaying the recipient ' s decision-making process on behalf of the Company. Any employee with questions about whether an intended payment or a gift is improper should consult a senior.

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Huhtamaki-PPL • Gifts and Entertainment

HPPL and its employees are allowed to provide and accept only modest and occas ional business courtesies that do not interfere with the recipient' s business judgment. Any employee uncertain on whether a gift is appropriately modest should seek the approval of the Head of the Department or the Chief Financial Officer (CFO).

• Money Laundering

HPPL does not participate in money laundering in any way whatsoever. If an employee encounters a situat ion or transaction in which the origin of the funds offered to HPPL is suspicious, the employee is expected to seek advice of his/her senior and the origin of the funds shall be verified to be acceptable before proceeding.

6. Working within the Company

• Corporate Governance

HPPL believes that good Corporate Governance is in itself a virtue and is also essential to achieve long term corporate goals and enhance stakeholder value. Thus, HPPL 's philosophy of Corporate Governance is aimed at adhering to the highest level of transparency, accountability and compliance with laws in all facets of operations, leading to best standards of Corporate Governance.

• Conflict of Interest

Employees are expected to strictly avoid conflicts of interest. A conflict of interest occurs when an employee has a personal interest or is involved in an activity that could interfere with his/her ability to

perform job in an objective, impartial and effective manner. An apparent conflict of interest occurs when personal interests or activities could lead others to doubt the objectivity or impartiality of the employee. Any such potential conflicts of interest are to be reported to a senior at the minimum level of Head of Department.

• Care of Company Assets

All HPPL 's assets shall be protected. Such assets may include, inter alia, all tangible and intangible assets, as well as other items such as the HPPL name and all of HPPL 's brand names, patents and trademarks, information. Employees must comply with Company travel and expense policies and safeguard all Company assets from loss through theft, carelessness, misuse or waste. Company assets are only to be used for authorised Company business.

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Huhtamaki - PPL Some assets, such as telephones and computers, may be used for limited personal purposes in accordance with HPPL policies, provided such use is appropriate, minimal and does not interfere with job performance.

• Corporate Authority

Employees of HPPL shall only make commitments they are authorized to make. If an employee is not sure about the limits of his/her authority, the employee shall consult his/her senior before making commitments on behalf of the Company.

• Insider Trading

Employees are prohibited from trading in HPPL shares or other securities carrying entitlement thereto based on inside information. ' HPPL [nsider Trading Code' and the stipulations of the SEBI (Prohibition of Insider Trading) Regulations, 1992 are to be followed strictly. The Compliance Officer/Company Secretary shall be contacted if an employee has questions about whether he/she may use particular information to make an investment decision. ·

• Accuracy of Business Records

HPPL maintains accurate records. Employees shall create, maintain, modify and dispose of business records only in accordance with HPPL policies. No false or misleading information is allowed to be included in any business records. Employees are prohibited from establishing or maintaining any Company accounts that are not recorded in the Company's books and records. Payments will be made only ifthey are supported by the required documentation and accompanied by the appropriate authorization. It is the responsibility of all the employees to report to their seniors any suspicions they may have about potentially fraudulent activities related to the business ofHPPL.

• Political Activity

As India is a democracy, we expect all employees to exercise their legitimate democratic rights. Every employee is, obviously, free to support the political party of his or her choice. Employees are free to participate in personal legitimate political activity, but the involvement must be on an individual basis, on their own time and at their own expense. Business decisions should never be influenced by such political involvement. Political activity at the workplace is prohibited.

• Equal Opportunity

Huhtamaki PPL welcomes diversity and treats its employees with dignity and respect. The company trusts and empowers individuals in their work and provides equal

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Huhta aki -PPL opportunity for all in recruiting, hiring, developing, promoting and compensation without regard to race, religion, caste, colour, age, gender, disability, veteran status or national origin.

• Professional Development

HPPL is committed to ensuring the continuous success, prosperity and development of the organization which can only be achieved through its people: by upgrading their skills and their competence, continuously providing motivation and encouraging and recognising their commitment. Thus employees are encouraged to upgrade their own knowledge and competence through education, self development and training to enable them to graduate to more demanding tasks and higher responsibility levels.

• Health & Safety

Employees are expected to actively contribute to HPPL's commitment to providing a healthy and safe workplace and to respect the environment and sustainability while carrying out all business operations. The company strives to provide a healthy and safe workplace for its employees, in accordance with applicable laws and regulations. The aim is to prevent accidents and mitigate health and safety risks with action programs. These action programmes are publicly communicated and continuous training is undertaken as per programs. Employees are required to comply with all workplace safety and environment related guidelines.

• Workplace Violence

At HPPL no workplace violence, physical, verbal, psychological or any other kind, is tolerated. Behaviour that is intimidating or threatening is likewise prohibited.

• Harassment

No sexual harassment, racial harassment and abusive behaviour is tolerated at HPPL.

An employee is expected to report all harassment to his/her senior or to the next higher level and HPPL shall take all necessary actions facilitated by local legislation to bring the offender to account. Retaliation against an employee reporting harassment is strictly prohibited.

HPPL has a Code on Sexual Harassment for reference and a Committee is in place to whom issues can be addressed.

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Huhtamaki - PP • Compensation

It is HPPL ' s philosophy to pay according to the relevant local market and provide market competitive total compensation to employees. HPPL will, at a minimum, comply with all applicable Labour Laws and Regulations, including those relating to minimum wages, overtime, maximum hours and other elements of compensation, and provide legally mandated benefits.

7. Donations

HPPL may, with approval of relevant designated authority in the company, donate moderate amounts of money or goods to support education, science, arts, culture or social welfare. Donations must be clear and the purpose of the donation must always be specified and known to HPPL.

8. Environment

HPPL aims to be an environmentally friendly company. The company aims at improving its performance through action programmes focusing on minimizing natural resource utilisation, optimizing process efficiency, applying the best available techniques and practices, and reducing solid waste generation, effluent discharges and emissions into the air. Above all the company actively supports, through appropriate communication and training, each individual's responsibility in environmental performance. HPPL will always comply with all government and statutory requirements on environmental protection.

9. Reporting of Violations of the Code - Whis~leblower Policy

If an employee becomes aware that another employee has violated this Code, the employee is expected to report the violation following the procedure as mentioned in the Whistleblower Policy.

10. Communicating with the Government and Public

As a public listed company HPPL is committed to making full, fair, accurate and timely financial disclosures to shareholders, authorities and public. To ensure that pub lic disclosures are handled properly. The Secretarial Department coordinates all such disclosures.

HPPL fully cooperates with requests for information from government officials and other authorities. The Legal Department is to be contacted before responding to any government requests/queries. Records or documents relevant to litigation or an investigation must never be altered, falsified, covered up, concealed, mutilated or destroyed.

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Huhta k1 -PPL 11. Confidentiality of Company Information

All non-public information abo ut HPPL is to be kept confidential. HPPL operates in competitive markets and has a vita l interest in protecting non-public information. Non­pub lic information includes any information about HPPL, its products, processes (proprietary and non-proprietary), practices, production facilit ies and techniques, customers, suppliers or employees that might be harmful for HPPL, if disclosed to external parties, or useful to HPPL ' s competitors. Such information includes, among other things, info rmation on products and product development, new product plans, pricing, revenue and profit figures, financial reports, marketing strategies, information relating to internal operations, future business plans, investments, R&D, potential acquisitions and disinvestments.

12. Amendment

The Company reserves its right to amend or modify this Code in whole or in part, at any time without assigning any reason. However, no such amendment or modification will be binding on the employees unless the same is notified to the employees in writing.

13. Others

Should you have any questions with respect to the Code, or about applying it to a particular situation, action or decision, do not hesitate to talk to your senior. In tum, seniors are responsible for ensuring that their repartees understand and act in accordance with the principles outlined in the Code.

Huhtamaki Speak Up channel is a new web-based system where you can report any suspected violations on the Code of Conduct , any other Huhtamaki policies or any laws or regulations. Speak Up channel is available at report.whistleb.comiHuhtamaki

Link to Speak Up can be found in Hub: In the Links section In Our work I How we work I Code of Conduct

We all have an important role in raising suspected violations

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Dr. Samar B Srivastava C hief People Officer

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Dr. Arup Basu M anaging Director

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