Think of this Code as the beginning of a conversation about making great decisions.

Every day in the course of business, we make countless decisions. Decisions that are big and small, unique and routine. Your decisions not only reflect your personal integrity, they define Avery Dennison.

Our Code of Conduct is built on our leadership principles and reflects our belief that being an ethical, values-based company is not only the right thing to do, but it's the only way to operate. The Code of Conduct is designed to encourage an ongoing dialogue about the choices we make every day.

As we navigate a complex business world, we can use this Code of Conduct to help us make decisions that embody our values, and are above all, ethical and legal. This mindset gives us a competitive advantage and sets us apart as a collection of diverse individuals, as an employer and as a corporate citizen.

The Code of Conduct is a tool to help you act with integrity, creating trust for everyone who interacts with our company – our people, customers, suppliers and our shareholders. The Code is not only for employees; it also applies to our directors and officers.

I encourage you to use the Code and our other Values and Ethics tools to make your mark.

Deon Stander

President and Chief Executive Officer

Some codes of conduct read like rule books.

This isn’t one of those. Instead, we clearly lay out our policies, expectations, and point of view, so that you can make the best decision in your particular situation, as circumstances demand.

Think of this code as the starting point of a conversation where we approach each situation thinking of the best way to set you up for success. This is why you will find that every section of the code is focused on you. Whether you need guidance on the expectations of being an employee, a coworker or a supervisor, or whether you need to reflect on how we act in the marketplace, in our communities or with the environment, you will find that our focus is always on helping you navigate the decision-making process to reach an ethical solution.

Remember that as you navigate your ethical decisions, you never have to do so alone. As part of our company values, teamwork and integrity go hand in hand. Ethical decisions are rarely easy or obvious and transparency necessarily drives discussion, challenges and questions, so please, reach out. Your manager, your Regional Ethics Counsel or a member of our legal team is always available to help. And never hesitate to use the Business Conduct GuideLine to seek guidance or report an ethics concern. Avery Dennison does not tolerate retaliation against anyone who makes a report in good faith. Read the Code. Understand our policies. Then bring them to life with every ethical choice you make. Doing so is an important part of what makes Avery Dennison a force for good. And it’s what Avery Dennison employees have proudly done for decades.

Diego Saul

Senior Director, Ethics and Compliance Officer