Ardagh Metal Packaging S A : Code of Conduct

Code of

Conduct

It's always the right time to do business the right way

Date: March 2024

Version: 5.0

Our Purpose and Core Values

Doing business the right way

We value our people	We act ethically and	We protect
and their safety	with integrity	our business

We care for our environment and communities

Resources

Contents
Message from the Chair
and CEO	3
Our Purpose and Core Values	4
Our Purpose	4
Our Core Values	5
Doing business the right way	6
What is our Code of Conduct?....6
Who does our Code apply ...to? 7
Our responsibilities	7
Manager responsibilities	8
Sanctions	9
Waivers	9
Getting help	9
Speaking up	10

We value our people and their
safety	11
Workplace Health and Safety....	11
Fundamental rights at work	13
Diversity, Equity and Inclusion....	14
Respectful workplace	14
We act ethically and with integrity...	16
No bribery and corruption	16
Gifts and hospitality	18
Conflicts of interest	20
Corporate Opportunities	21
Accurate financial reporting	21
Insider Trading	23
Competition and anti-trust
compliance	25
Sanctions and export control
laws	26

We protect our business	27
Preventing fraud	27
Safeguarding our physical
assets	28
Protecting our confidential
information	29
Protecting our IT systems	30
Data privacy	31
We care for our environment and
communities	32
Valuing our environment	32
Focusing on sustainability	33
Supporting our communities...	34
Respecting human rights and
promoting social responsibility in
our value chain	35
Resources	36

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Our Purpose and	Doing business	We value our people	We act ethically and	We protect
Core Values	the right way	and their safety	with integrity	our business

Message from the Chair and CEO

We care for our environment and communities

Resources

We at Ardagh Metal Packaging ("AMP") are committed to operating in an ethical and honest way and complying with all applicable laws.

Our Code of Conduct has been prepared to provide guidance for our business and all those with whom we work. It sets out the framework of how we should deal with each other and our customers, suppliers and stakeholders. Crucially, our Code of Conduct is built around our Purpose: "We make packaging for good" and our Core Values of Inclusion, Trust, Teamwork and Excellence.

or that of any other person, we encourage you to speak up and share your concerns. In the first instance you should raise issues with your line manager. Alternatively, you may contact a member of Group Legal

• Compliance or raise your concerns anonymously through our Speak-Up Hotline.

Working in line with our Code of Conduct will enable us to continue building a business of which we can all be proud, and which reflects our ongoing commitment to our customers and our respect for each other.

Our Code of Conduct applies to all our employees. Every employee is responsible for reading and following it. If you have any questions or concerns about your own conduct

Herman Troskie	Oliver Graham
Chair of Ardagh Metal	Chief Executive Officer
Packaging S.A.	Ardagh Metal Packaging

3

Our Purpose and Core Values

Doing business the right way

We value our people	We act ethically and	We protect
and their safety	with integrity	our business

We care for our environment and communities

Resources

Our Purpose and Core Values

Our business environment is constantly changing. However, what will not change is our commitment to our Purpose and our Core Values. These define who we are as a company and form the foundation of our business. They demonstrate our commitment to our customers, suppliers and stakeholders, and our respect for each other.

Our employees share much more than a strong brand and an excellent reputation. We each share a common Purpose

• We make packaging for good. Our Purpose enables us to deliver customer innovation, provides an inspirational environment for our teams and drives our business through growth and development.

The future we're creating is built around our four Core Values of Inclusion, Trust, Teamwork and Excellence. We are committed to conducting our activities with the highest standards of integrity.

Our Purpose

We make packaging for good

4

Our Purpose and Core Values

Doing business the right way

We value our people	We act ethically and	We protect
and their safety	with integrity	our business

We care for our environment and communities

Resources

Our Core Values

Inclusion	Trust
Inclusion ensures we are mindful of others, inviting	Trust is earned by displaying attributes that show
contributions from everyone and valuing our diversity of	we are respectful, reliable, consistent and honest
thought. We all need to be comfortable and confident to	in our approach to others. It is built on mutual
be ourselves while at work.	respect, personal integrity and transparency.

Teamwork	Excellence
Teamwork is achieved with collaboration and	Excellence is our continual pursuit of
communication. Working together as one team enables	self-improvement through learning and
us to identify hazards, work safely and prevent incidents.	development, as well as our commitment to
Teams should be mindful of the impact their decisions	elevate the business to greater heights.
have on other teams, and the business.

Inclusion

Trust

Teamwork

Excellence

5

We are committed to operating with the highest standards of integrity and honesty.

6

Our Purpose and Core Values

Doing business the right way

We value our people	We act ethically and	We protect
and their safety	with integrity	our business

We care for our environment and communities

Resources

Doing business the right way

What is our Code of Conduct?

We are committed to operating with the highest standards of integrity and honesty and to complying with all applicable laws and regulations in all dealings within our business, with others (including customers, suppliers and public authorities), and with the communities in which we operate. Our Code of Conduct (our "Code") is the framework for achieving this commitment and sets out principles and clear expectations about what we consider acceptable behaviours.

The principles in our Code are not intended to be all- inclusive, but they do provide the necessary guidance on our established way of doing business. Throughout our Code you will see references to various related key policies. In addition to these, further policies and guidelines supplement or implement the principles of our Code. Any such policies or guidelines, whether issued at group, business or local level, are available via

our intranet, myArdagh, and must be followed.

Our Code should be used as a guide for conducting business in a compliant, honest

and professional manner and should be considered in determining all business decisions and actions. By doing so, we strengthen our business, create and maintain a culture based on our Core Values, and ensure that we are doing business in the right way.

Our Purpose and Core Values

Doing business the right way

We value our people	We act ethically and	We protect
and their safety	with integrity	our business

We care for our environment and communities

Resources

Doing business the right way

Who does our Code apply to?

Our Code applies to everyone in our business, including all AMP's directors, officers and employees worldwide (collectively "employees") in all of our global AMP companies and any joint ventures controlled by AMP. We also expect that all our business partners adhere to the principles and values set out in our Code. Our Code always applies while we are working on AMP premises, at off-site locations while conducting AMP business or at any place where we are representing AMP.

action is appropriate. If you ever see or suspect any conduct that is in violation of, or inconsistent with, our Code, you should immediately speak up.

You are also expected to be familiar with the legal and regulatory requirements that are applicable to your business responsibilities and to fulfil your duties in accordance with them. Questions concerning the applicability of any laws or regulations should be directed to Group Legal & Compliance.

Our responsibilities

We are all responsible for meeting the highest standards of integrity by reading and complying with our Code. You should make sure that you understand both the principles set out in our Code and any policies implementing these. Seek advice from your line manager, Human Resources or Group Legal & Compliance if you do not understand, need clarification or if you are unsure whether your proposed course of

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Our Purpose and	Doing business	We value our people	We act ethically and	We protect
Core Values	the right way	and their safety	with integrity	our business

Doing business the right way

Manager responsibilities

We care for our environment and communities

Resources

If you are a manager, you must act as a role model, always setting a good example for your team and demonstrating your commitment to the principles set out in our Code through both your actions and words.

Managers have a special responsibility to act with the highest standards of integrity.

You are responsible for building an ethical culture and making sure your team understands how to live by our principles. Where employees come to you with questions or concerns, you should address and respond to these promptly, and where necessary escalate issues. You should also seek guidance where you are unsure of the proper course of action, or would benefit from another perspective, and you must always speak up and report behaviours that are unethical or inconsistent with our Code.

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Our Purpose and Core Values

Doing business the right way

We value our people	We act ethically and	We protect
and their safety	with integrity	our business

We care for our environment and communities

Resources

Doing business the right way

Sanctions

Failure to comply with our Code, our policies and applicable laws may result in disciplinary action. Such action will always be in accordance with applicable law, and may include training, counselling and termination of employment. In addition, we may bring violations of criminal laws to the attention of the appropriate law enforcement authorities.

Waivers

In the unlikely circumstance that a waiver to our Code should become necessary, you must contact the Company Secretary. Any waiver by a director or officer requires prior approval from Ardagh Metal Packaging S.A.'s board of directors.

Getting help

Our Code covers many scenarios, but it is not exhaustive. If you need any assistance in understanding our Code, you should ask your line manager or a member of Human Resources. If you are still unclear, you can ask a member of Group Legal & Compliance.

Here are some questions that you can ask yourself to see whether behaviours or practices are compliant:

Is this legal?

Is this consistent with our Code of Conduct and policies?

Does this look and feel right?

Could this harm your or our reputation?

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Our Purpose and Core Values

Doing business the right way

We value our people	We act ethically and	We protect
and their safety	with integrity	our business

We care for our environment and communities

Resources

Doing business the right way

Speaking up

It is crucial that you speak up if you see or suspect any violation of our Code, our policies or the law. You should first raise concerns with your line manager. If you are uncomfortable with doing this for any reason you can contact a member of Human Resources or Group Legal & Compliance.

Another avenue to report concerns is via our "Speak- Up Hotline". Our Speak-Up Hotline is operated by an independent third-party and allows all employees the opportunity to report concerns in a confidential, secure and effective manner. Subject to local laws, reports may be made anonymously. Our Speak-Up Hotline can be accessed online via ardaghgroup.ethicspoint.com, and via local toll-free numbers in all the countries in which we operate. More information on accessing our Speak-Up Hotline is set out in the Resources section at the end of

this Code, together with contact details for Group Legal & Compliance.

We take all concerns reported seriously and reports received via the Speak-Up Hotline will be handled by qualified investigators.

No retaliation

We will not permit retaliation of any kind for reporting information in good faith, which means telling the truth as you believe it to be. You can report concerns about violations of our Code, or other any other illegal or unethical conduct, without the fear of retaliation or discrimination, including without the concern that you might be disciplined or considered for dismissal as a result of speaking up.

Related policy:

Speak-up and Whistleblowing Policy

Suspect a breach of our Code of Conduct? You can speak to:

• Your line manager
• Human Resources
• Group Legal & Compliance
• Our Speak-Up Hotline

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