You + the workplace


You + the marketplace


You + the world


You can show the world that ethical business is good business. Your ethical leadership sets the tone in our relationships with suppliers and other business partners. By putting the company’s interests ahead of your own, by treating all of our business partners fairly and by setting the expectation of ethical conduct, you make it clear that we do what’s right.

Suppliers and Partners

Conflicts of interest

Your actions carry weight. As you navigate potential conflicts of interest at work, the choices you make shape our future. Sometimes, you can recognize a potential conflict immediately: for example, your brother owns a company that Avery Dennison is considering as a supplier. But even when the conflict is less obvious – or when it just looks like there might be a conflict of interest – how you choose to handle it affects the company’s reputation, as well as your own.

Any situation that risks influencing your professional judgment, or has the potential to lead to a perception that your professional judgment may be affected, is a conflict of interest you need to disclose. In business decisions, we all have an obligation to put the company’s interest ahead of personal interests. Disclose any potential conflict of interest to your manager or the Law Department and in the annual Compliance Certification.

Investments and business relationships

We are careful to avoid any relationships that might influence, or appear to influence, our judgment when conducting business on Avery Dennison’s behalf. In general, we should not personally do business with or compete with the company, nor should we own an “interest” in any company that does business with or competes with the company. An “interest” is at least one percent of the total ownership of a company, or an investment with a market value of $100,000 or more. And the same is true for our close relatives. These interests may be allowed in some circumstances but only after getting approval, as described in Conflict of Interest (Policy 7.12).

Gifts, meals and entertainment

Although the exchange of gifts, meals and entertainment is common in many business relationships, we are careful to avoid the appearance that they might improperly influence business transactions.

Gift-giving customs and gift policy thresholds can vary from region to region and between types of customers. But, regardless of local custom, we never offer or give anything of value to any government official without prior approval from the Law Department. We also do not accept any gift, meal, entertainment or anything else of value that could reasonably be thought to influence our business judgment. If we are offered such a gift, meal or entertainment, we report it to the Law Department as soon as possible.

This is a complex issue. See Conflict of Interest (Policy 7.12) for a full discussion.

Second jobs

We demonstrate our commitment to Avery Dennison by making our jobs our primary focus. We’re more effective if we don’t divide our time and energy between the company and secondary jobs. If circumstances arise that make a second job necessary, inform your supervisor, who will follow the procedures outlined in Secondary Employment (Policy 2.12) to get prior approval. If you are required to complete the annual Compliance Certification, disclose any secondary employment you have.

If we have a second job, we’re careful to make sure it doesn’t interfere with our efficiency, attendance or job performance at Avery Dennison. We also never accept outside employment at any printing business, adhesive products business, or any business competing with or purchasing from or selling to any company business unit.

Corporate opportunities

We don’t take for ourselves business that rightfully belongs to Avery Dennison. If we discover business opportunities through Avery Dennison – whether through the use of company property, information, or position – we refer them to the appropriate area of the company. By not competing with the company, directly or indirectly, we fulfill our duty to advance Avery Dennison’s business interests whenever possible, in accordance with Legal and Ethical Conduct (Principle 1.1) and Conflict of Interest (Policy 7.12).

Supplier standards

By extension, our suppliers are part of Avery Dennison’s culture, so we do our best to hold them to the same ethical standards we follow. They are bound by Avery Dennison’s Global Supplier Standards, which detail the best practices and ethical behavior we expect from our suppliers.

We also do our best to hold suppliers responsible for ensuring that any subcontractors that produce goods or services for us meet these standards, including these important points:

  • We do not permit our suppliers to use child labor or forced labor.
  • We require suppliers to provide employees with a safe and healthy workplace and to operate in compliance with all local environmental, health and safety laws.
  • We do not allow any kind of bribe, kickback or other form of personal payment tied to our business arrangements.
Questions and Answers

What exactly is a “conflict of interest”?


A conflict of interest is when your private interests (what’s personally best for you or a friend or close relative) are different, or appear to be different, from what’s best for Avery Dennison. For example, if you have to fly for work, it might be best for you to book with an airline that gives you extra reward miles. But a different airline might have a less expensive flight available, and therefore be better for the company.


When it comes to conflicts of interest, who counts as a close relative?


We define a close relative as a spouse, domestic partner, parent, grandparent, parent-in-law, child, grandchild, brother, sister, brother-in-law, or sister-in-law, whether or not living in your household.

Customers and Markets

Sales and marketing

We rely on the quality of our products and services to win sales, not unethical tactics. That means

  • We sell our products and services honestly.
  • We do not engage in misleading or deceptive marketing practices.
  • We never make false statements about our competitors or their products.
  • If we discover that we have created a misleading impression, we correct it.

Fair dealing in the marketplace

We deal fairly with all commercial parties. We do not take advantage of anyone – including competitors – through theft, manipulation, misrepresentation, or any other illegal or illicit act. We do not give or take payments or other items of value to influence the awarding of a contract or other business transaction.

Competitive intelligence

We treat our competitors with respect, and we treat their intellectual property with the same care we give our own. We may collect, share and use information about our competitors, but we do so legally and ethically. We may, for example, gather and use information from publicly available filings with government agencies, public speeches made by company executives, annual reports and published articles. We do not accept, share, or use any competitive information that we believe was gathered or disclosed inappropriately.


We always comply with antitrust laws, which promote fair competition in the marketplace and require competitors to compete on equal terms. Antitrust laws may be violated if we enter into an agreement – whether explicitly or impliedly through our actions – with a competitor that restricts competition or unreasonably restrains trade. Do not agree with competitors to fix prices, allocate customers or territories, coordinate contract bids (known as “bid rigging”), limit production capacity, or deny supplier or customer relationships – these activities restrict competition and are illegal.

Even the appearance of improper agreements with competitors can harm our reputation, so we never discuss with competitors any of the following:

  • pricing,
  • terms and conditions of sales,
  • allocation of customers or territories, or
  • any other subject affecting competition.

Our company has some customers of one business unit that are competitors with that same business unit or a different business unit. For guidance on how to deal with those customers, contact the Law Department.

Because of the risk of violating antitrust laws in interacting with competitors, we don’t participate in trade associations without prior Law Department approval.

This subject is complex. As a starting point, become familiar with Antitrust Compliance (Policy 7.9) and what it means for you. In addition, web-based training is periodically provided to employees. Consult the Law Department before you talk with competitors to assess and address antitrust or fair competition concerns.

Questions and Answers

How do I approach discussions at trade shows with competitors who are also customers or suppliers?


Carefully. Limit your discussions to the extent possible and restrict them to the purchase or sale relationship of your business unit. Never try to influence another business unit that competes with the customer or supplier. Even harmless conversations with competitors can appear to violate antitrust laws. Consult the Law Department for guidance before you attend trade shows with customers or suppliers who are also competitors.


If a customer volunteers our competitor’s price, can I offer a lower price?


Maybe. You can always match a competitor’s price, but offering a price that is less may not be legally permissible. It depends on the circumstances, including whether you are offering that lower price to all customers. Contact the Law Department for help with the situation.


Can I ask a customer what she’s currently paying for a product that we’re trying to supply?



The Quick 5

When the right decision isn’t obvious, check your course of action against these questions. If you answer “no” to any of them, seek a different course of action. If you answer “maybe” or “I’m not sure” ask your manager or the Regional Ethics Counsels for their opinion.


Is my decision consistent with our Code?


Is it ethical?


Is it legal?


Would I want my friends and family to know I made this choice?


Would I want to read about this decision on the Internet?