Modern Slavery Report January 1, 2024 to December 31, 2024 Sonoco Products Company
This Modern Slavery Report (the “Report”) addresses the period from January 1, 2024 to December 31, 2024 and has been prepared in compliance with the Fighting Against Forced Labour and Child Labour in Supply Chains Act (Canada) (the “Act”). This Report is made on behalf of Sonoco Products Company (“SPC”) and its subsidiary, Sonoco Canada Corporation (collectively “Sonoco,” the “Company,” “we,” “our,” or “us”). Information contained on the websites referenced in this report is not part of, or incorporated by reference into, this report.
1. Introduction
Forced labour and child labour, each as defined in the Act, are crimes and serious violations of human rights. As a leading developer, manufacturer, and seller of a wide variety of packaging products, Sonoco recognizes the important role that we have in ensuring that our operations and products, and the supply chains that support such operations and products, adhere to the highest ethical standards, including the prevention and identification of forced labour and child labour in our supply chains. This Report sets out the steps we have taken in 2024 to prevent and reduce the risk of forced labour or child labour being used
in the production of goods we produce in Canada or elsewhere or import into Canada.
2. Our Business
Sonoco business in Canada is conducted primarily through Sonoco Canada Corporation, a wholly owned direct subsidiary of SPC. SPC is a packaging company headquartered in the United States.
SPC is a global provider of highly engineered and sustainable packaging products serving multiple end markets. SPC sells rigid paper containers, metal packaging, and industrial paper packaging to Canadian customers.
Sonoco Canada Corporation is a manufacturing company with operations in Edmonton, Alberta; Chatham, Ontario; Brantford, Ontario; Mississauga, Ontario (which ceased operations in September 2024); Cap de Madelaine, Quebec; and Saint John, New Brunswick. Sonoco Canada Corporation manufactures and sells paper, converted paper, and rigid paper products. Sonoco Canada Corporation procures goods and services from approximately 120 external suppliers and contractors. The suppliers Sonoco Canada Corporation engages include businesses that produce certain raw material inputs, including recycled paperboard, adhesives, metal ends, and chemicals for producing paper and converted paper products.
In addition, other Sonoco entities are suppliers and customers of Sonoco. Further information about Sonoco businesses can be found in SPC’s Annual Report on Form 10-K, subsequent Quarterly Reports on Form 10-Q, its other filings with the U.S. Securities and Exchange Commission, and its website at www.sonoco.com.
3. Our Policies
Policies
Through SPC’s organizational and governance policies, we communicate our values and expectations, setting a high bar for ourselves, our suppliers, and our selling partners, and make it clear that we do not tolerate any forms of forced or child labour in any of our operations or those of our suppliers. We make diligent efforts, including through carrying out due diligence and audits to monitor the performance of our suppliers, to prevent our activities from having a negative impact on human rights. Our relevant policies are discussed in further detail below:
Policies on Business Conduct
We are committed to conducting our business in a lawful and ethical manner. Our Policies on Business Conduct (the “Policies”) are the foundation of our companies’ policies and set out guiding principles on professional conduct and establish that Sonoco employees should always act lawfully, ethically, and in the best interests of Sonoco in performing their job duties. Sonoco is committed to the core values of honesty, integrity, and accountability. This commitment requires that employees and directors of Sonoco comply fully with all laws, rules, and regulations that apply to Sonoco’s business operations, and that they act honestly and ethically. Our Policies are available on our Investor Relations website at www.investor.sonoco.com.
Supplier Standards
Sonoco’s Supplier Standards detail the requirements and expectations we have of our suppliers, their supply chains, and any of their contractors with whom we engage. We expect our suppliers to comply with all applicable legal requirements in the jurisdictions in which they operate and to consistently monitor and enforce our Supplier Standards in their own operations and supply chains. Our Supplier Standards also set forth other standards that are important to us, including, among others, our principles of environmental awareness, non-discrimination, human rights, safety, and accountability. We require our suppliers to commit to our Supplier Standards as a condition of doing business with us.
Sonoco’s Supplier Standards confirm respect for human rights as a basic tenet of Sonoco’s beliefs, and its commitment to principles including (i) the elimination of forced or compulsory labour and human trafficking, (ii) the establishment and maintenance of fair and safe work environments, and (iii) the requirement that all suppliers operate such that employee working hours are in compliance with local standards as well as local and national laws and regulations of the applicable jurisdiction. Under the Supplier Standards, Sonoco will not work with any suppliers who require employees to work in excess of statutory limitations without proper compensation as required by applicable law. Further, Sonoco condemns all forms of exploitation of children and forbids the use of children in the workforce. Suppliers are forbidden from recruiting child labour, and all supplier employees are required to be above the legal employment age in the country of their employment.
We review our Supplier Standards on a periodic basis to ensure that this policy is in line with current best practices. Our Supplier Standards are available publicly on our website at www.sonoco.com/about/supplier-resources/supplier-standards.
Human Rights Policy
Sonoco’s Human Rights Policy outlines Sonoco’s commitment to respect human rights standards; specifically, those outlined in the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labor Organizations Declaration on Fundamental Principles and Rights at Work. Sonoco’s Human Rights Policy applies to all operations of the Company, including all divisions, subsidiaries, and affiliated companies as well as all employees, directors, officers, agents, contractors, business partners, vendors, and suppliers of Sonoco. Our Human Rights Policy is available publicly from our website at www.sonoco.com/about/supplier-resources/human-rights-policy.
Sonoco’s Internal Audit Department monitors Sonoco’s compliance with the Human Rights Policy.
Corporate Sustainability Report
Sonoco's 2024 Corporate Sustainability Report underscores our dedication to sustainable packaging, industry leadership, and employee wellbeing. Our sustainability initiatives in energy efficiency, renewable energy, waste reduction, and water management aim to significantly reduce greenhouse gas emissions. We strive to promote strong human rights and ethical procurement practices in our supply chains by setting clear supply chain expectations and complying with legal protocols set forth in laws such as the California Transparency in Supply Chains Act and the conflict minerals requirements under the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act. For employees, we promote well-being, and career development through extensive training programs and fair practices. The full report can be found on our website at www.sonoco.com/na/sustainability/reports.
Due Diligence
We expect third parties with which we work to adhere to business principles and values similar to our own and to comply with all applicable laws and regulations. Before making any commitments towards third parties and as part of our process for onboarding potential new suppliers, we take steps to appropriately evaluate the relationship and mitigate associated risks by carrying out risk-based due diligence and checks.
Two of Sonoco Canada Corporation’s facilities participate in the Supplier Ethical Data Exchange (“SEDEX”), a non-profit organization that helps businesses improve ethical and responsible business practices in their supply chains. Other Sonoco manufacturing locations currently participate in SEDEX with various levels of involvement. In total, across Sonoco globally, approximately 60 individual operations participate in SEDEX. Each of the participants have completed SEDEX’s Self-Assessment Questionnaire, and Sonoco is participating in SEDEX Members Ethical Trade Audits (“SMETA”) in some locations. Many of Sonoco’s customers and suppliers are also members of SEDEX. Sonoco is considering expanding its participation in the SEDEX platform, including SMETA, to further evaluate and assess supply chain risks in the future.
We acknowledge the risk of forced labour or child labour in our facilities and our supply chains. To mitigate this risk, we follow a due diligence approach that includes requiring compliance with all Sonoco Policies, conducting internal and third-party audits of Sonoco facilities and operations, and reviewing SEDEX information and SMETA results.
4. Assessing Our Risk
We recognize that we may be indirectly linked to a risk of modern slavery because of our business activities in the manufacturing and packaging industry, and that certain sectors in our supply chain (including the provision of materials, contractors, and labour) may pose a higher risk of modern slavery. Sonoco has established various policies and procedures designed to identify, assess, and manage supplier risk. To assess the risk of forced labour and child labour in our business and supply chains, we conduct risk assessments and review data provided by customers and suppliers. To identify the business activities with the greatest exposure to these risks, we consider the following factors:
- Reliance on low skilled workforce;
- Presence of migrant workers;
- Long, complex, or non-transparent supply chains; and
- Jurisdictional risks including poverty, conflict, and enforcement of international human rights standards.
Sonoco seeks to manage modern slavery risks through a variety of policies, processes, and practices, which are outlined in this Report.
5. Our Commitments
Steps to Prevent and Reduce Risks of Forced and Child Labour
During the reporting period, Sonoco took the following steps to prevent and reduce risks of forced and child labour:
- Continued to leverage the results of a 2023 internal Human Rights Risk assessment of forced labour and/or child labour in our operations and supply chains;
- Developed and implemented an action plan for addressing any identified instances of forced labour and/or child labour;
- Maintained internal controls to ensure that all workers are recruited voluntarily;
- Developed and implemented due diligence policies and processes for identifying, addressing, and prohibiting the use of forced labour and/or child labour in our operations and supply chains;
- Maintained child protection policies and processes;
- Continued the use of anti-forced labour and/or child labour contractual clauses;
- Maintained anti-forced labour and/or child labour standards, codes of conduct, and/or compliance checklists;
- Incorporated modern slavery- and human rights-related topics into our annual Code of Conduct training for all salaried employees, and committed to continuing to include these topics in future trainings;
- Monitored suppliers;
- Maintained grievance mechanisms; and
- Engaged with supply chain partners on the issue of addressing forced labour and/or child labour.
Human Rights Risk Assessments and Management Tools
2023 Human Rights Risk Assessment
In 2023, we conducted a Human Rights Risk Assessment (the “2023 Assessment”) to monitor compliance with our Human Rights Policy in accordance with methodologies informed by the United Nations Guiding Principles on Business and Human Rights, the International Labor Organization, and the U.S. Department of State’s Bureau of Democracy, Human Rights, and Labor. The 2023 Assessment focused on ensuring the following: (i) fair and safe work environment, (ii) the rights of children and the abolition of child labour, (iii) prohibiting forced or compulsory labour and human trafficking, (iv) non-discrimination, (v) freedom of association and collective bargaining; and (vi) indigenous people’s rights. The 2023 Assessment included interviews covering broad topics, including human rights risks and priorities, policy and awareness, risk mitigation efforts, and supplier due diligence. We intend to conduct another Human Rights Risk Assessment in 2026.
In connection with the 2023 Assessment, we also sampled a selection of 20 suppliers to assess the nature and extent of due diligence, onboarding, and procedures as they relate to human rights. This included review of current supplier contracts, attestations of suppliers to the Supplier Standards, recent bidding or due diligence activities, and any publicized human rights violations related to the supplier.
Third-Party Human Rights Risk Management Dashboard
In 2024, Sonoco implemented a third-party human rights risk management dashboard to more closely monitor compliance with our Supplier Standards by our significant suppliers. The dashboard uses insights from Freedom House, a nonprofit organization that rates access to political rights and civil liberties in approximately 210 countries and territories through its annual “Freedom in the World” report. We used the dashboard to identify suppliers located in countries or territories rated as “partially free” or “not free” that may be asked to review and agree to our Supplier Standards on a more frequent basis than those located in countries rated as “free.” By monitoring the risk profiles of our most significant supplier relationships on an ongoing basis, we aim to communicate more transparently with customers and other stakeholders about human rights conditions in our value chain.
Third Party Risk Management Program
As part of our third-party risk management (“TPRM”) program, we leverage external data monitoring and reporting capabilities through a managed third-party solution. A component of this service aggregates data from a variety of leading data providers to monitor various risks, including compliance risks. Through this compliance risk monitoring program, we receive information, refreshed monthly, on risks related to sanctions, enforcement actions, and adverse media, which we review as part of our efforts to prevent and identify incidents of modern slavery. If modern slavery issues are identified in our supply chain, they are communicated to Sonoco management for awareness and to determine the next course of action. In our risk rating methodology, human rights violations or related issues (which include instances of modern slavery) are assigned a “Very High” risk rating. This is the most severe risk rating used in our risk methodology and is subject to the most extensive and urgent escalation procedures to relevant Sonoco management.
Remediation Measures
Sonoco has not identified any forced labour or child labour in its operations or supply chains in Canada, and therefore, no remediation measures have been taken. If a situation of non-compliance is identified in the future, we are committed to implementing remediation measures to correct the situation and improve the enforcement of our prevention measures within our business and supply chain.
Training
Sonoco requires all employees to acknowledge Sonoco’s code of conduct at the time of hiring and requires all salaried employees to participate in annual trainings on Sonoco’s code of conduct. Over 98% of Sonoco’s salaried employees completed the 2024 annual Code of Conduct training, which covered a variety of topics, including modern slavery, whistleblowing, and global supply chain management. Sonoco intends to include human rights as a topic for the 2025 Code of Conduct training.
6. Our Progress and Effectiveness
As part of our governance processes, which include our TPRM program, we monitor compliance with our policies on an ongoing basis. We also review any concerns raised through formal and informal mechanisms of employee feedback. To date no significant concerns or complaints have been identified.
We are committed to developing relevant metrics to evaluate the effectiveness of our TPRM program as it continues to evolve.
7. Approval & Signature
In accordance with paragraph 11(4)(b)(ii) of the Act, this joint Report was approved by SPC’s Board of Directors on May 27, 2025, on behalf of itself and its wholly-owned subsidiary, Sonoco Canada Corporation, and has been submitted to the Minister of Public Safety and Emergency Preparedness in Canada. This joint Report is also available on our company website at www.sonoco.com.
In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in this joint Report for Sonoco Products Company and Sonoco Canada Corporation. Based on my knowledge, and having exercised reasonable diligence, I attest that the information in this joint Report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above.
Theresa J. Drew
Director, Audit Committee Chair
May 27, 2025
I have the authority to bind Sonoco Products Company