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We know that making ethical choices isn’t always easy. That’s why we offer support, training and resources to help you feel more confident in your choices. Your manager, Human Resources, Group Ethics Counsel or another member of the Law Department, the Business Conduct GuideLine, and other sources of help are always available.


Compliance with laws

Compliance is the foundation. Each of us needs to understand – and comply with — the laws, regulations and policies that apply to our particular jobs. But compliance is just the beginning. Sometimes, it’s possible to follow the letter of the law but not do what’s right. That’s contrary to our philosophy. At Avery Dennison, we strive for the highest ethical standards.

Responsibility of employees

The standard of integrity we set for ourselves means that we aim to follow the letter and spirit of the law. Gaining the knowledge and understanding to do that takes time and energy. Consider it a critical investment in your own success and the future of our company.

Responsibility of managers

Managers have additional responsibilities. They lead by example, model appropriate conduct and ensure that employees understand the Code and other policies. As part of their responsibilities, managers

  • set the tone by emphasizing the importance of ethical business practices and upholding our values,
  • talk about the Code with their employees using Talkabout Toolkits and other resources to demonstrate how our ethical standards affect the way we do business,
  • encourage employees to come forward with concerns, appropriately escalate any reports received from their team members, and do not retaliate against employees who raise concerns, and
  • take action quickly – by promptly talking to Human Resources or the Law Department – if they see or hear that the Code or a law might have been violated.

Making values-based decisions

This Code show Avery Dennison’s values in action. Every time you make a choice as an employee, you bring the Code to life. So even when you’re pressed to get the job done quickly, we want you to take the time to do it right and be safe. That means taking the time you need to choose words and actions that are consistent with our shared purpose and standards, and acting with integrity.

Asking questions and getting help

Do you have questions? Tough questions? You’re not alone. When you are not sure about making the best choice, we are ready to help you make smart, ethical decisions. A full list of resources are available under ‘Ask a Question’.

Reporting concerns

It takes all of us working together to maintain our standards of integrity. Avery Dennison trusts – and expects – you to speak up if you see or suspect a violation of the law or our Code. Bring your concerns to a member of management, Human Resources, your Group Ethics Counsel or another member of the Law Department or our Business Conduct GuideLine. Our company takes seriously all reports and will appropriately investigate. We will protect confidentiality to the extent possible to conduct a thorough investigation.

Our company understands that speaking up about a concern can feel uncomfortable. That’s why we prohibit retaliation against anyone who, in good faith, reports a potential violation of the law or our Code. Retaliation is conduct that brings professional harm to an employee and may take many forms. If you see or suspect retaliation against anyone for raising a concern, report it immediately to your manager, any other member of management, Human Resources or the Business Conduct GuideLine (anonymously, if you choose). Together, we can maintain a workplace where everyone feels free to speak up.

See Non-Retaliation (Policy 2.15) for more information.

Questions and Answers

What should I do if a local law seems inconsistent with the Code?


It’s rare that such a situation happens. If it does, contact the Law Department.


I’d like to consult the Law Department on a decision, but won’t that slow things down?


The key is to involve the Law Department early on; it will speed up the process if they are involved in the beginning stages.


I didn’t mean to violate the Code, but I discovered that I did. Will I get in trouble if I tell my manager?


Most mistakes can be prevented by investing time and attention in reading and exploring the Code and understanding corporate policies. But mistakes happen, and it’s always better to tell your manager as soon as you realize it so the matter can be addressed.


Equal opportunity

Avery Dennison is committed to treating every employee fairly and with respect. That means we provide equal opportunity to all employees and applicants. We prohibit unlawful discrimination or harassment because of race, color, religion, sex, pregnancy, national origin, ancestry, citizenship, age, marital status, physical disability, mental disability, medical condition, sexual orientation, gender identity or expression, veteran status or any other status protected by law. In making employment decisions, we focus on individual qualifications, demonstrated skills, abilities and achievements, and other factors relevant to the job.

See Equal Employment Opportunity and Affirmative Action (Policy 2.1) for more information.


Harassment has no place at Avery Dennison. We do not tolerate verbal or physical harassment, bullying or any behavior that can create an intimidating, offensive, abusive or hostile work environment. Our company has a “zero tolerance” policy against all forms of harassment. We show respect for ourselves and each other by speaking out when a coworker’s conduct makes us – or another coworker – feel uncomfortable.

For information on reporting harassment, see Harassment and Violence-Free Workplace (Policy 2.8).

Workplace violence

At Avery Dennison, we don’t do or say anything that could

  • Threaten the safety or security of any coworker or anyone else
  • cause damage to company or personal property, or create fear.

We are all entitled to feel safe at work, and we take responsibility for each other by promptly reporting anything that might threaten or harm another person.

Environment, health and safety

Workplace safety is of the utmost importance at Avery Dennison. Each of us is responsible not only for our own health and safety but also for that of our coworkers and the working environment. This means that we make responsible choices – even when doing so may be difficult – and promptly report accidents, injuries and unsafe practices and conditions. Everyone is responsible for knowing how to perform his or her job safely and in compliance with the law.

Environmental Protection, Health and Safety (Policy 1.4) and Employee Health and Safety (Policy 2.5) detail our shared responsibilities for health and safety.

Drug-free workplace

Avery Dennison is a drug-free workplace. We all have an obligation to report to work – whether on or off company premises – free from the influence of any substance that could prevent or impair us from performing our jobs safely and effectively.

Substance Abuse (Policy 2.7) explains when and how drug and alcohol testing take place.


We do not participate in hiring decisions involving relatives or anyone with whom we are romantically involved. Where these individuals work for our company, they generally cannot work within our “sphere of influence or control,” meaning they cannot report directly or indirectly to us. We tell our managers when relatives or romantic interests are or may potentially become employed by the company.

For more information, see Anti-Nepotism (Policy 2.16).

Questions and Answers

If I bring up my safety concern now, it will slow down production, and we may miss our deadline. I don’t want my supervisor to be upset with me. What do I do?


Deadlines are important, but health and safety always come first. We’re all committed to this priority. The company wants you to bring up concerns immediately, even if that means slowing production, missing a deadline or losing a business opportunity.


I think my coworker might have a drug problem. If I report him, will he be fired?


Not necessarily. Avery Dennison recognizes that alcohol and drug dependence are treatable conditions. Human Resources and our Employee Assistance Program can help employees overcome abuse. But employees who use or are under the influence of drugs or alcohol at work may be subject to discipline in order to keep everyone at Avery Dennison safe.

The Company

Business and financial records

We are committed to being open, accurate and honest in all company records and information.

Accurate accounts and records

The accuracy of our business records is critical for effective decision making. Accuracy is also critical to shareholders, governments and other stakeholders outside the company to whom we report. Our books and records must fairly and accurately reflect all business transactions.

We follow the law and all company internal controls. We never falsify documents, including financial accounts, quality reports, time sheets, travel and expense reports, and other submissions (such as benefits claim forms and resumes). We treat all company documents as if they may one day be subject to public scrutiny. All reports to regulatory authorities are complete, fair, and accurate.

Records and information management

Proper management of company records preserves the vital flow of information within our company while minimizing risk from outdated information. We maintain records only as long as we are using them, unless law or Records Retention and Protection (Policy 7.21) requires us to maintain them longer.

Assets and information

We use company assets and information appropriately. We understand that information – whether ours or someone else’s – should only be used legally and ethically.

Protection and proper use of company assets

Avery Dennison assets belong to the company for the operation of our business, and not to us individually or to anyone outside the company. We do not misuse or waste these assets, including company funds, equipment, products, employees’ work product, proprietary information, patents and trademarks. We are naturally suspicious of requests for money or information from sources we don’t know or trust.

We maintain communication and data management systems, including computers, phones and internet access, for business use. We don’t use these or any other company assets for personal businesses, entrepreneurial endeavors, or for improper purposes. We can use the internet and phones for reasonable personal use, as long as it doesn’t interfere with our work duties.

Protection of proprietary information and intellectual property

Much of the information we create or use in our company is confidential and provides us with significant value. Wrongful or inadvertent disclosure could harm our ability to compete. Improper disclosure may also be a violation of the law. We keep safe our confidential and proprietary information and share it only when necessary. We take appropriate precautions to protect the confidentiality of our information and that of others entrusted to us. Our obligation to protect this information continues even after our employment with the company ends. Refer to Protection of Confidential and Proprietary Information (Policy 7.13) for more information.

In the course of our work, we may create materials that become the intellectual property of the company. We protect the intellectual property of our company, including all patents, copyrights and trademarks. We secure patents for company inventions to give us exclusive rights to manufacture our products. Copyrights protect the written materials and publications we develop in our work. Our logo is an example of a symbol protected as the trademark of the company. Patents (Policy 7.16), Copyrights (Policy 7.17), and Trademarks (Policy 7.18) provide more detail.

Individual privacy and personal data

Protecting information is a basis of trusting relationships. We respect the privacy of others and protect personal data. This includes information we possess concerning employees, customers, consumers and others.

Protecting individual privacy and personal data is important to our company. We don’t release private information about employees, customers or others with whom we interact to outsiders or even to those within the company who do not have a legitimate business need to know. In certain situations, it can be illegal to transmit personal information. If you receive a request for personal information about an employee, customer or other business associate, direct the request to your Human Resources representative. The principles around data privacy protection are implemented through a variety of measures, including IT security, Disclosure of Employee Information (Policy 2.11) and the European Union Data Protection policy.

Confidential information of others

We also take care with the confidential information of other companies. We treat this information with the same respect we give our own and use it only for the purpose for which it was disclosed to us. We don’t want to possess, use or benefit from other companies’ confidential information without their authorization. That includes confidential information that an employee obtained through prior employment or activities outside their scope of work.

Insider trading

Sometimes, in the course of our work, we learn about important information regarding the company that is not known publicly. Examples of this kind of information include significant capital projects, litigation developments, technological advances or new products, or acquisitions and divestitures. Trading in company stock on the basis of this “material nonpublic information” – or informing others of the information so that they may do so – is called insider trading. Insider trading is illegal. It distorts the market and damages trust. We do not use financial or other confidential information, or disclose it to family members or others, for the purpose of trading in stocks or other securities. Refer to Insider Trading (Policy 7.10) for more information.

Questions and Answers

Does Avery Dennison read my company email or listen to my voicemails?


The company does not, as a rule, monitor your business communications. But Avery Dennison may monitor the information that passes through company systems, including email, voicemail, internet browsers, internal social media communications and computer hard drives, to the extent permitted by local law.


What exactly is “confidential information”?


Confidential information is any information that the company hasn’t disclosed or made available to the public. Information about inventions, contracts, pricing, new products, prototypes, proposals, financial data, business plans or strategies, and employees are a few examples. Others include corporate earnings reports or forecasts that haven’t been released to the public, research and development results or information about our relationships with other companies.

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?