A diverse team of representatives from Human Resources, Finance and the Legal Department collectively manages, reviews and implements each policy. As part of our continuous improvement processes, we regularly review and revise our policies to strengthen language, address emerging risks and evolving regulations and conform with best practices. Greif’s Global Regulatory Steering Committee, assembled in 2022, is responsible for identifying and proactively addressing regulatory changes and risks. We also leverage training and audits to effectively implement our policies, requiring each of Greif’s over 3,300 manager-level and above colleagues to complete policy training. In 2023, we will look to better track training data and make content easier to digest. We encourage our colleagues to anonymously report ethics and compliance violations through our Ethics Hotline. A third-party provider administers the Hotline to protect the anonymity of our colleagues and is available 24/7. We include information on the Hotline and related policies in the Code of Conduct, on which all colleagues receive training through Greif University. Hotline information is also shared through posters at each facility. Complaints can be reported via an online portal or e-mail and by phone globally. Greif’s Ethics Hotline policy assures that no retaliation can be made after a complaint is filed. All reported incidents are sent to our Ethics Committee, chaired by Greif’s General Counsel, for review. Incidents are reported quarterly to the Audit Committee of Greif’s Board of Directors. In 2022, we investigated 207 reports (100 percent) and resolved 99.5 percent of the complaints from our Ethics Hotline.

We conduct annual Sarbanes-Oxley Act (SOX) audits to validate the compliance of our established policies. This encompasses all facilities that are material to our financial statements. Each year we ensure that facilities accounting for at least 75 percent of our revenue are included in our Sarbanes-Oxley scope. In total, Greif had 260 auditable entities in 2022. To supplement required SOX audits, we conduct risk-based audits at each facility at least once every five years. Facilities are identified for audits through a multi-layered process that includes management surveys, discussions, approval by executive leadership and reports to the Ethics Hotline. In 2022, we completed 17 risk-based audits following this process. As we standardize processes across global operations, we will continue strengthening our internal control capabilities related to facility audits.

Greif also considers global trends and events when viewing ethics and compliance. In 2022, the EU and European and other authorities imposed sanctions related to the Russia-Ukraine conflict. Greif established an EU Sanctions Steering Committee to discuss and implement sanction compliance measures. Our Corporate Legal Department advises and monitors sanction laws continuously. Greif also developed procedures and trained colleagues to comply with sanction laws. We will continue to monitor this risk and ensure compliance with these evolving sanctions. Additionally, as we have fully integrated our response to COVID-19, global and regional task forces meet on an as-needed basis to develop protocols, communications and monitoring mechanisms to ensure the health and safety of our colleagues and maintain compliance with national and local regulations. As the pandemic endures, we will continue to track cases and enforce safety precautions at our facilities.