Code of Business Conduct
Conflicts of Interest

Employees and Board members must avoid financial, business or other relationships that might be opposed to Winpak's interests or might cause a conflict with the performance of their duties. All employees shall conduct themselves in a manner that avoids even the appearance of conflict between their personal interests and those of Winpak. Examples of situations to avoid include:

• Travel, entertainment and gifts (other than gifts of $50.00 or less) from suppliers or potential suppliers.
• Serving as a director, officer, partner, employee, consultant, or in any other key role in an organization, which does or seeks to do business with Winpak, or is a competitor or customer of Winpak. Serving on the Board of Directors of an organization other than the foregoing may be a conflict and therefore requires the advance approval of the Board of Directors. Helping the community by serving on Boards of non-profit organizations is however encouraged and does not require prior approval.
• Any interest (other than nominal shares in publicly-traded companies) in any supplier, customer or competitor of Winpak.