Item 10. Directors, Executive Officers and Corporate Governance

The Company’s Code of Conduct (the “Code of Conduct”), is applicable to all employees, including the principal executive officer,

principal financial officer, principal accounting officer, and controller, and all directors. The Company’s Code of Ethical Conduct for

Directors and Senior Financial Officers (the “Code of Ethics”), is applicable to our directors and its Senior Financial Officers, that is,

its principal executive officer (“CEO”), its principal financial officer, and its principal accounting officer, as well as any other senior

executive or senior financial officers who may be specifically designated from time to time by the CEO (the Code of Conduct and the

Code of Ethics together, the “Codes”). The Codes are available at https://www.smurfitwestrock.com/about/corporate-governance/

policies. To the extent required by the rules of the SEC or the NYSE, Smurfit Westrock intends to disclose amendments to and

waivers of the Codes applicable to executive officers and directors, if any, on that website within four business days following the date

of any such amendment or waiver.

Additional information responsive to this Item is incorporated herein by reference to our definitive proxy statement with respect to our

2025 annual general meeting of shareholders to be filed with the SEC within 120 days after the end of our fiscal year covered by this

Annual Report on Form 10-K.