California Transparency in Supply Chains Act of 2010

As required by this law, Greif published a report on the measures it is taking to prevent and eliminate forced labor in our direct supply chain.

Disclosure Statement for California Transparency in Supply Chains Act of 2010

On and after Jan. 1, 2012, certain companies manufacturing or selling products in the State of California are required to disclose their efforts, if any, to address the issue of slavery and human trafficking, per the California Transparency in Supply Chains Act of 2010. This law requires each of those companies to provide information disclosing their efforts to eradicate slavery and human trafficking from its direct supply chain, thereby allowing consumers to make informed choices regarding the products they buy and the companies they choose to purchase from.

Slavery and human trafficking can take many forms, including forced labor and child labor.

Greif has addressed these issues in its supply chain in many ways. For example:

• Greif has identified employees who have direct responsibility for supply chain management and has implemented and conducted internal training and on-line training on human trafficking and slavery, particularly with respect to identifying and mitigating risk within the supply chain.
  
  
• Greif employees visit the manufacturing facilities of our suppliers from time to time. This provides the Company with the opportunity to review the actions of our suppliers and to ask questions regarding their conduct.Presently, the Company does not verify product supply chains to evaluate and address risks of human trafficking and slavery or audit its suppliers.
  
  
• Greif has supply agreements and purchase orders that, where possible, require our suppliers to warrant that the products we purchase from them are produced in material compliance with all laws and regulations applicable to such supplier, to the goods being purchased and to the conditions of their production. We reserve the right to terminate our relationship with a supplier in the event of non-compliance with this warranty. Presently, our contracts do not specifically require our suppliers to certify that they comply with laws regarding slavery and human trafficking of the country or countries in which they are doing business.
  
  
• All Greif directors, officers and employees are subject to the provisions of the Greif, Inc. Code of Business Conduct and Ethics, which requires compliance with all applicable laws, rules and regulations.Violations of the Code of Business Conduct and Ethics are subject to disciplinary action up to and including termination of employment. The Company does not currently maintain standards regarding slavery and human trafficking for its suppliers.