Standards of
Business Conduct
Our Mission
To inspire and nurture the human spirit—one person, one
cup, and one neighborhood at a time.
Our Values
With our partners, our coffee and our customers at our core, we
live these values:
Creating a culture of warmth and belonging, where
everyone is welcome.
Acting with courage, challenging the status quo and
finding new ways to grow our company and each other.
Being present, connecting with transparency, dignity and
respect.
Delivering our very best in all we do, holding ourselves
accountable for results.
We are performance driven, through the lens of humanity.
Our Mission and Values
2
Look Inside
3
Living Our Values 4
Anti-Retaliation Policy 5
The Workplace 6
How We Treat One Another 7
Diversity 8
Wage and Hour Rules 8
Business Practices 10
Conicts of Interest 11
Gifts and Entertainment 12
International Business 13
Interaction with the Government 13
Sales Practices and Advertising 15
Fair Competition 15
Our Responsibilities 16
Securities 17
Condential Information 18
Intellectual Property 19
Use and Retention of Company Records 20
Protecting Partner and Customer Personal Data 20
Books and Records 21
Financial Accounting, Internal Controls and Auditing Matters 21
Political Activities 21
Compliance with Laws and Regulations 22
Frequently Asked Questions 24
Making the Right Decision 26
Speaking up 28
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Living Our Values
Anti-Retaliation Policy
Starbucks does not tolerate retaliation against or the victimization of any partner who
raises concerns or questions regarding a potential violation of the Standards of Business
Conduct or any Starbucks policy that he or she reasonably believes to have occurred.
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Why do the Standards of Business Conduct (Standards) Exist?
As a global company, we are subject to the highest standards of ethical
conduct and behavior
The Standards help us make decisions in our daily work
The Standards demonstrate that we take our legal and ethical responsibilities
seriously
Who is Expected to Follow the Standards?
The Standards apply to all partners, officers, and board of directors, as well as
temporary service workers and independent contractors
We also expect that third parties working on our behalf will follow similarly
high ethical standards
As Partners, We Need to Know:
Know and follow the Standards and company policies that apply to our jobs
Ask questions when we are unsure of the right course of action
Speak up when we see or suspect misconduct
Leaders and Managers Set the Tone
Set high expectations for partners and lead by example
Foster an open-door culture where partners feel comfortable asking questions
and reporting concerns
Be alert to possible misconduct in the workplace
Promote ethics and compliance through continued learning opportunities
Anti-Retaliation Policy
Starbucks does not tolerate retaliation against or the victimization of any partner who
raises concerns or questions regarding a potential violation of the Standards of Business
Conduct or any Starbucks policy that he or she reasonably believes to have occurred.
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The Workplace
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How We Treat One Another
Consistent with our Global Human Rights Statement, Starbucks promotes equal
opportunity in its hiring practices, makes recruiting decisions based solely on job-related
criteria and does not use forced labor.
When employing partners under the age of 18, managers must comply with
all Starbucks-established or legally required limitations on minimum hiring
age, and on hours and tasks performed by these partners to ensure any work
performed does not hamper the partner's education, health, safety, and mental
or physical development.
All partners are entitled to work in an environment that is free of harassment,
bullying and discrimination. Harassment, bullying and discrimination take many
forms, including:
Unwelcome remarks, gestures or physical contact
The display or circulation of offensive, derogatory or sexually explicit
pictures or other materials, including by email and on the Internet
Offensive or derogatory jokes or comments (explicit or by innuendo)
Verbal or physical abuse or threats
All partners are entitled to work in an
environment that is free of harassment,
bullying and discrimination.
Q: One of my co-workers emailed an inappropriate joke to me and some
teammates. I find it offensive, but I don’t know if I should approach my
co-worker with my concern. What should I do?
A: We each have an obligation to ensure that Starbucks is a great place to work
for all partners, and offensive behavior such as this is not acceptable. If you
feel uncomfortable speaking with your co-worker directly, contact your
manager, Partner Resources or Ethics & Compliance.
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Diversity
Starbucks actively creates and promotes an environment that is inclusive of all people
and their unique abilities, strengths and differences, and promotes diversity as a
strategic and competitive business advantage for the company.
We respect diversity in each other, our customers and suppliers and all others with
whom we interact. Our goal is to be one of the most inclusive companies globally,
working toward full equity, inclusion and accessibility for those whose lives we touch.
Wage and Hour Rules
We are committed to following all applicable wage and hour laws and regulations. To
help ensure that all work performed for Starbucks is compensated correctly, partners
compensated on the basis of hours worked must report and record time accurately in
accordance with established local procedure.
Q: Lately my store has been very busy and it has been hard to find time to
do routine cleaning. At this morning’s store meeting, our manager told
everyone that if they don’t complete their tasks before they punch out
they will have to stay off the clock” to do so. Is it okay for our manager
to ask this of us?
A: No. Working off the clock is strictly prohibited by Starbucks. Starbucks is
committed to ensuring that all partners are accurately compensated for all
work performed. Any requests to work off the clock must be reported to
Partner Resources or Ethics & Compliance.
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Q: Lately my store has been very busy and it has been hard to find time to
do routine cleaning. At this morning’s store meeting, our manager told
everyone that if they don’t complete their tasks before they punch out
they will have to stay off the clock” to do so. Is it okay for our manager
to ask this of us?
A: No. Working off the clock is strictly prohibited by Starbucks. Starbucks is
committed to ensuring that all partners are accurately compensated for all
work performed. Any requests to work off the clock must be reported to
Partner Resources or Ethics & Compliance.
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Business Practices
Q: I have a relative I’d like to hire to do some work at Starbucks. Since it’s a
legitimate project that needs to be done, and my relative is trained to do
this type of work, is it okay if I hire her?
A: Although the work is legitimate, this situation creates the appearance of a
conflict. The circumstances of this situation should be raised with Ethics &
Compliance so that an independent review can be done prior to committing
to a contract. This will help protect you, your relative and Starbucks if the
relationship ever comes into question.
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Conflicts of Interest
We all must avoid conflicts of interest. A conflict of interest exists when
a personal interest or activity interferes or appears to interfere with the
duties that you perform at, or owe to, Starbucks. A conflict of interest may
unconsciously influence even the most ethical person and the mere appearance
of a conflict may cause a partners acts or integrity to be questioned.
In addition to annual disclosure, potential conflicts of interest must be disclosed
to the partners manager or the vice president in charge of the partners
department or business unit, who will contact the chief ethics and compliance
officer (CECO). If preferred, disclosure can be made directly to the CECO via
Ethics & Compliance. Members of the Board of Directors should disclose
actual, potential or apparent conflicts of interest to the Chair of the Audit &
Compliance Committee.
Some examples of situations in which conflicts of interest may arise:
Being employed by or operating a firm, including consulting, that does or
desires to do business with Starbucks or that competes with Starbucks
(for example, working in a competitor’s coffee shop)
Making a substantial direct investment in such a firm (by you or a
member of your immediate family)
Acting on behalf of anyone besides Starbucks in any transaction with
Starbucks (for example, helping someone sell products and/or services
to Starbucks)
Engaging personally in transactions in which Starbucks has an interest
Q: I have a relative I’d like to hire to do some work at Starbucks. Since it’s a
legitimate project that needs to be done, and my relative is trained to do
this type of work, is it okay if I hire her?
A: Although the work is legitimate, this situation creates the appearance of a
conflict. The circumstances of this situation should be raised with Ethics &
Compliance so that an independent review can be done prior to committing
to a contract. This will help protect you, your relative and Starbucks if the
relationship ever comes into question.
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Gifts and Entertainment
A gift or favor should not be accepted or given if it might create a sense of
obligation, compromise your professional judgment or create the appearance of
doing so. In deciding whether a gift is appropriate, you should consider its value
and whether public disclosure of the gift would embarrass you or Starbucks.
A gift of money should never be given or accepted. (Some retail partners,
however, may accept customary tips for service well done.) A gift of nominal
value may be given or accepted if it is a common business courtesy, such as
coffee samples, a coffee cup, or a similar token.
Trading items of value with other businesses, including shops and restaurants, is
strictly prohibited. Starbucks prohibits offering, giving, soliciting or receiving any
form of bribe or inducement. There are serious penalties for engaging in this
conduct.
Partners may offer or accept meals and entertainment if they are reasonable
and customary, appropriate, occur infrequently and are not expensive.
Please consult the travel and/or expense guidelines for your business unit or
department for additional guidance.
You may not encourage or solicit meals or entertainment from anyone with
whom Starbucks does business or from anyone who desires to do business
with Starbucks. Giving or accepting valuable gifts or entertainment might be
construed as an improper attempt to influence the relationship.
“Giving or accepting valuable gifts or
entertainment might be construed as an
improper attempt to influence the relationship.
Q: May I accept a business meal from a supplier?
A: In most circumstances, modest and infrequent business meals may be
accepted. However, whenever a supplier pays for a meal, always consider the
specific circumstances and whether your impartiality could be compromised
or appear to others to be compromised. If the meal is offered during contract
negotiations, you must always politely decline the invitation. Talk with your
manager if you are unsure.
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International Business
Partners must comply with all local and foreign laws regarding customs
and trade. Starbucks will be accurate and truthful in representing business
transactions to government agencies. All information that a partner furnishes to
any customs official or to any agent hired by Starbucks to facilitate imports and
exports must be accurate and truthful.
If you conduct business internationally on behalf of Starbucks, please make
sure you have a thorough understanding of these laws and know enough about
any third parties doing business in Starbucks name to ensure they are making
appropriate decisions on our behalf.
Starbucks partners at no time are permitted to
influence the outcome of any business decision
by exchanging bribes or kickbacks of any kind.
Interaction with the
Government
Starbucks policy is to deal honestly and fairly
with government authorities and to comply with
valid governmental requests and processes.
Payments made to any foreign agent or
government official must be lawful under
the laws of the United States and the foreign
country. Payments by or on behalf of Starbucks
to foreign agents or government officials should
always be strictly for services rendered and
should be reasonable in amount given the
nature of those services.
Q: A vendor I work with just finished an important project for me on time
and under budget. I would like to show my appreciation with a gift.
What is appropriate?
A: When we give gifts, we set the tone for how we conduct business—purely on
business considerations. Keep this in mind when selecting a gift for a vendor.
Also take into consideration their company’s gifts and entertainment policy.
Just as we want others to respect our standards, we want to be mindful of
theirs.
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It is against Starbucks policy (and may be a breach of law) to offer or make a
payment or gift of any kind in order to facilitate a local process or to influence
a local government official. Under no circumstances may a partner make
payments in violation of the law or to induce a government official to do
business with Starbucks.
If you are contacted by a government or regulatory representative and asked
to provide information or submit to an inspection, you should inform your
manager immediately. Your manager will take appropriate actions or contact
the appropriate department for guidance.
We must be truthful and straightforward in our dealings with the government
and may not direct or encourage another partner or anyone else to provide
false or misleading information to any government official or representative.
Partners must not direct or encourage anyone to destroy records relevant to an
investigation.
Certain partners will be notified and trained on a regular basis for the purposes
of compliance with relevant federal laws, including those regarding lobbying
disclosure, anti-bribery and anti-corruption.
We must be truthful and straightforward in our
dealings with the government.
Q: We use an agent to facilitate relations with local government officials.
Recently he asked us to increase his commission, and I suspect he wishes
to pass this money on to the local officials. What should I do?
A: If you suspect that the agent is making illegal payments on Starbucks behalf,
the company is under an obligation to investigate whether this is the case
and to halt any such payments. You should report your suspicions to your
manager or Ethics & Compliance.
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Sales Practices and Advertising
Starbucks competes on the merits of our products and services in all sales and
advertising. Our communications with our customers or potential customers
must be truthful and accurate. When we say something about our products and
services, we must be able to substantiate it. We sell the quality of what we do;
we do not disparage our competitors.
Fair Competition
Fair competition laws are intended to promote vigorous competition in a free
market. It is in Starbucks best interest to promote free and open competition.
Starbucks must make its own business decisions, free from understandings
or agreements with competitors or suppliers that restrict competition. We
consider compliance with these laws of vital importance.
When conducting Starbucks business, all partners must:
Not discuss pricing, production or markets with competitors
Not set resale prices with customers or suppliers
Always present Starbucks services and products in a manner consistent
with our core values
Not induce a third party to breach an existing agreement
Never act in a manner that could be seen as an attempt to exclude
present or potential competitors or to control market prices
Q: A salesperson for a competitor and I are friends. Occasionally we talk
about marketing plans. Should I be concerned?
A: Yes. You are revealing confidential information that Starbucks has invested
time and money to develop. You also may be violating competition laws that
ban discussions of marketing and pricing.
Q: I am going to a trade show. May I go to a competitor’s booth?
A: Yes. You may go to the booth and collect any publicly distributed material.
However, if you talk to anyone at the booth, identity yourself as a Starbucks
partner, and avoid conversations about business. If you have any questions,
a good practice is to consult Law & Corporate Affairs for guidance before you
attend.
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Our Responsibilities
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Securities
As a partner, you may become aware of significant and confidential information
about Starbucks business, often called “material non-public information.
Partners may not buy or sell stock (including by cashless exercise of stock
options) or any other security while in possession of this information. In order
to avoid any potential problems, you should interpret the term “material non-
public information broadly.
Some examples of material information include:
Financial information
The development of new products or services
A proposed acquisition, joint venture or merger
Government investigations
Changes in key personnel
Information is considered to be non-public unless it has been adequately
disclosed to the public. Examples of effective disclosure include public filings
with securities regulatory authorities and the issuance of company press
releases.
There also must be adequate time for the market to digest the information.
Starbucks requires that the information must be publicly available for at least
one full business day before you may trade in Starbucks securities. Directors,
certain executives and partners with regular access to material non-public
information also may not trade during the blackout periods established by
Starbucks.
For more information, refer to the Insider Trading Policy, which can be obtained
by contacting Ethics & Compliance.
Q: My family and friends often ask me about Starbucks and whether they
should buy stock. Usually I tell them what I know about our business and
suggest they buy stock. Is this a problem?
A: The same rules about inside information apply whether you buy or sell stock
yourself or if you give the information to someone else—known as “tipping.
If a relative or friend buys or sells stock based on non-public information
that you give him or her, both of you could be liable for violation of securities
laws. Furthermore, you could be in violation simply for sharing material
non-public information, regardless of whether or not he or she uses it or
benefits from it.
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Confidential
Information
Starbucks information should be
used only for company purposes
and should not be disclosed to
anyone outside of the company.
Even within the company, only
those individuals who truly need
to know the information to
conduct their business should
have access to confidential
information. If you leave
Starbucks, you must return all
company materials and property,
and any copies.
Confidential information includes things such as supplier information, Starbucks
technologies, recipes, formulas, coffee blends, business and marketing plans,
internal company communications, and existing and future product information.
Confidential materials should:
Be stored in a secure place and should not be left out where others can see
them
Be clearly marked as confidential
Not be sent to unattended fax machines, scanners or printers
Not be discussed where others may hear
Starbucks is committed to being fair in the areas of confidential information and
materials. Just as we take care to protect our information, Starbucks respects the
information of others.
Here are some basic rules to follow:
Do not bring any material from prior employers to Starbucks
Do not accept or use anyone else’s confidential information (or agree to
maintain anyones information in confidence)
Do not solicit confidential information from another companys present or
former employees or suppliers
Do not engage in espionage; be transparent in obtaining information
about the marketplace
Intellectual Property
As a partner, the things you create for Starbucks belong to the company. This
includes inventions, discoveries, ideas, improvements, software programs,
artwork and works of authorship. This work product is Starbucks property if it
is created or developed, in whole or in part, on company time, as part of your
duties or through the use of company resources or information. Partners must
promptly disclose to Starbucks, in writing, any such work product and cooperate
with the company’s efforts to obtain protection for Starbucks.
To ensure that Starbucks receives the benefit of work done by outside
consultants, it is essential that an appropriate written agreement or release be
in place before any work begins.
Remember, too, that our brands, including the Starbucks name, are extremely
valuable to Starbucks success. Brands are fragile and must be used carefully
and protected from misuse. Consult Starbucks guidelines for proper trademark
usage.
When Starbucks uses the work product of others, including art and music,
we must also be sure to follow the rules. For example, you should only use
software for which you have a valid license and should only use that software
in accordance with the terms of the license for that software. Written materials
and music may be subject to copyright protection and should be copied only
when permitted. Use caution, as not all copyrighted materials bear a notice.
Q: I am able to get an early start on my day by returning calls during my train
ride to work. Is this a problem?
A: You must be careful not to discuss non-public company information in
public places where others may overhear you, such as taxis, elevators or at
conferences and trade shows. When it is necessary to conduct a telephone
call in a public place, be mindful of your surroundings.
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“Brands are fragile and must be used
carefully and protected from misuse.
Use and Retention of Company Records
Starbucks Information and Records Management Standard states that partners will manage
information in such a way that supports the needs of the business while ensuring efficiency,
security and compliance with any legal or regulatory requirements. This standard applies to
records maintained in all forms at Starbucks, including paper and electronic.
If you are responsible for preparing or maintaining any Starbucks records, please
familiarize yourself with the Starbucks Information Protection Services Handbook, the
Starbucks Records Retention Schedule and specifically the retention periods that apply to
the records you keep. Also remember that there are strict rules relating to the processing
and handling of private and secret information. This includes collecting, storing, using,
amending, disclosing and destroying information.
Records must always be prepared accurately and reliably, and stored properly in
accordance with the Starbucks Records Management Handbook and the Starbucks
Records Retention Schedule.
Records must accurately and fairly reflect, within Starbucks normal accounting and
reporting systems, all required transactions and other events.
There cannot be any unrecorded company funds, assets or any other type of off
the books” accounts, no matter what the reason for such accounts.
You must not knowingly destroy or discard information that is subject to a legal hold.
Records relevant to a legal action cannot be destroyed or discarded and must be
preserved. If Starbucks receives a subpoena (or other form of legal order), a request
for records or other legal papers, or if we have reason to believe that such a request or
demand is likely, the company policy is to retain all information that is relevant to the
matter.
Protecting Partner and Customer Personal Data
Starbucks maintains many information assets, including personal and sensitive information,
which are critical to doing business, keeping the trust of our customers, and keeping our
future strong. This personal information may reside on digital computing systems, networks
or backup devices, or may be recorded on paper or other recording media.
Starbucks Global Privacy Standard requires that all collection, storage locations, uses,
sharing, transfers, and disclosures of personal data be strictly controlled and protected.
Additionally, reasonable effort must be made to ensure that fundamental privacy and
security principles are followed across the enterprise when managing personal information
of both partners and customers.
Reasonable effort includes:
Ensuring compliance with all applicable international, federal, state/provincial and
local laws and regulations as well as applicable contractual agreements;
Protecting the rights of our customers, partners, and business contacts; and
Protecting Starbucks from the risk of a data breach.
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Any suspected data privacy incidents must immediately be reported to the Global Privacy
Office at [email protected] or to your local help desk.
Books and Records
All partners must ensure the accuracy and integrity of Starbucks corporate records. This
includes reliability and accuracy of books and records, as well as full, fair, accurate, timely
and understandable public disclosure.
The books of account, financial statements and records of Starbucks should be
maintained in accordance with the requirements of law and generally accepted
accounting principles. All of Starbucks assets and liabilities should be properly
recorded in its books, and revenues and costs must be recorded in the right time periods.
Financial Accounting, Internal Controls and Auditing Matters
Concerns regarding accounting, internal accounting controls or auditing matters should be
promptly reported through the Ethics & Compliance Helpline. Reports may be made
anonymously and will be treated in a confidential manner.
Depending on how they are classified, reports of this nature will be routed to Ethics &
Compliance, the chief ethics and compliance officer or the general counsel in Starbucks
U.S. head office, the Audit and Compliance Committee of the Board of Directors or the
presiding independent director of the Board.
Political Activities
Political activities must be conducted on your own time and using your own resources.
You must not promote any political or personal views or beliefs (including by posting or
distributing notices or other materials) on or around Starbucks premises, and you may not
indicate or suggest that you speak for Starbucks or that the company supports your views.
Compliance with Laws
and Regulations
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Starbucks is committed to full compliance with the laws, rules and regulations of
the countries in which it operates. You must comply with all applicable laws, rules
and regulations when performing your duties.
When you think a conflict exists between the Standards and an applicable law,
rule or regulation, or if you have a question concerning the legality of your or other
partners’ conduct, you should consult with your manager or Ethics & Compliance.
The standards and policies stated herein are not all the applicable Starbucks
standards and policies nor are they a comprehensive or complete explanation
of the laws that are applicable to Starbucks and its partners in any particular
country. All Starbucks partners have a continuing obligation to familiarize
themselves with applicable laws relating to their job responsibilities and all
Starbucks policies. Breach of these standards, Starbucks policies or the law may
give rise to disciplinary action up to, and including, dismissal.
Any waiver of the Standards of Business Conduct requires the prior written
approval of the chief ethics and compliance officer or, in certain circumstances,
the Board of Directors or a committee thereof. If required by applicable law,
waivers will be promptly disclosed as required by applicable law.
The standards and policies discussed herein may be amended from time to time.
Partners should access the Standards of Business Conduct posted at
https://LivingOurValues.Starbucks.com for the most current version.
This information is available in accessible formats. For more information contact:
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Frequently Asked
Questions
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Q: What happens when a concern is reported through the Helpline?
A: Concerns reported through the Helpline are received by a third party.
Partners speak with a trained specialist by phone regarding their questions or
concerns or complete a customized Web form online. The report is forwarded
to an Ethics & Compliance partner who works with the appropriate party or
department for investigation and any appropriate action.
Please be aware that information provided to Ethics & Compliance is directed
to the United States. Every reasonable effort will be made to protect the
security of any personal data collected and to avoid unauthorized use or
disclosure of such data.
Q: May I contact the Helpline anonymously?
A: Yes. You will be given a unique report number, which will allow you to
anonymously check on the status of your report. Concerns reported to the
Helpline are not traced and are handled in a confidential manner.
We encourage partners to provide their names and contact information
because reports in which those details are not provided can be more difficult
to investigate. Starbucks cannot guarantee your anonymity if you identify
yourself or give information from which you can be identified, but we will
take every reasonable precaution to assure that the partner’s identity
remains as confidential as possible.
Q: Can I be retaliated against or victimized for using the Helpline?
A: Starbucks does not tolerate retaliation against or the victimization of any
partner who raises concerns or questions regarding a potential violation of
Starbucks policy that he or she reasonably believes to have occurred.
Q: Who may I contact for more information or to obtain policies?
A: Contact your local Partner Resources representative or Ethics & Compliance
via email at EthicsAndCompliance@Starbucks.com.
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Making the Right
Decision
1. Identify the ethical problem
List possible solutions and any obstacles to
resolving the problem.
2. Seek input from others, if appropriate
3. Determine the best approach
Is it consistent with Our Mission and Values and
any applicable law or regulation?
Would your approach embarrass you or
Starbucks?
How would your approach look published in the
media?
Would you be comfortable with the example it
sets for future decisions?
4. If the path isn’t clear, ask for guidance
5. Follow through on your decision
You Are Empowered
You can deliver great customer experiences, knowing that Starbucks supports
you in doing the right thing and conducting business with integrity.
You Have Responsibility
You play a critical role in ensuring that Starbucks is a great work environment
and in protecting our culture, our reputation and our brand.
You Have Help
If you are unsure of what to do in a situation, you have resources available to you,
including Partner Resources and Ethics & Compliance.
You Have a Voice
When you think something isn’t right, speak up and share your concerns,
knowing that Starbucks wants to hear them and does not tolerate retaliation
against partners.
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Speaking up
The Ethics & Compliance Helpline is a resource available to partners to ask questions
or raise concerns. The Helpline is available 24 hours a day, seven days a week, and an
interpreter can be made available upon request.
Ethics & Compliance Helpline
Online
www.Starbucks.com/Helpline
By Phone
Americas
United States 1-800-611-7792
Canada–English 1-800-611-7792
Canada–French 1-866-614-0760
Costa Rica 0800-011-0928
Asia Pacific
Hong Kong 800-90-8032
Japan 0120914499
China
China 400-990-1441
Europe, Middle East and Africa
Austria dial 0-800-200-288, then enter 800-913-4991
France 0-800-91-5128
Italy 800797110
Netherlands 0-800-020-0908
Switzerland 0-800-56-1170
United Kingdom 0-800-028-3528
Areas That Do Not Yet Have a Local Helpline Number
To place a free call to the Helpline or as a backup for numbers above, please contact
your local operator and ask to place a “reverse charge” or collect call to the United
States, number 678-250-7560. If you would like to place your call anonymously,
please say “Miss Starbucks” or “Mister Starbucks” when the operator requests your
name.
Email
EthicsAndCompliance@Starbucks.com
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This brochure is made with 30% post-consumer material.