EX-1.01 2 exhibit101.htm EXHIBIT 1.01 Exhibit


Exhibit 1.01
Sealed Air Corporation
Conflict Minerals Report
For the Year Ended December 31, 2017
Introduction
This Conflict Minerals Report has been prepared pursuant to Rule 13p-1 of the Securities Exchange Act of 1934, as amended (the “Rule”), for the reporting period from January 1 to December 31, 2017. This Conflict Minerals Report describes Sealed Air Corporation’s (“Sealed Air,” the “Company,” “we,” “our,” or “us”) reasonable country of origin inquiry (“RCOI”) and due diligence on the source and chain of custody of gold, columbite-tantalite (coltan), cassiterite, wolframite, or their derivatives, which are limited to tantalum, tin and tungsten (“3TG” or “Conflict Minerals”) that are necessary to the production or functionality of products that Sealed Air manufactured or contracted to manufacture during calendar year 2017 (the “2017 Report Year”). We are several steps removed from the mining and processing of the 3TG used in the components for our products. Accordingly, our due diligence process focused on our suppliers, and we rely on them to assist with both our RCOI and due diligence process, including the identification of smelters or refiners (“SORs”) in the supply chain and the countries of origin of 3TG sourced by the identified SORs.
The information in this report covers the activities of Sealed Air and all of its consolidated subsidiaries.
Company Overview
Sealed Air, a corporation organized under the laws of Delaware, is a global leader in food safety and security and product protection. The Company serves an array of end markets including food and beverage processing, food service, retail, and commercial and consumer applications. Our focus is on achieving quality sales growth through leveraging our geographic footprint, technological know-how and leading market positions to bring measurable, sustainable value to our customers and investors.
Product Description
This Conflict Minerals Report relates to products (i) for which 3TGs are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during calendar year 2017. Through a screening process, the Company determined that, to the best of our knowledge, customer equipment and other select products from the Company’s three divisions, Food Care, Product Care and Diversey Care, referred to collectively as the “Covered Products,” contain 3TG or have a high likelihood of containing 3TG, as these products contain electronic components. More specifically, the “Covered Products” may contain necessary 3TGs as follows:
Tantalum, used in capacitors and certain alloys;
Tin, used in soldered components;
Tungsten, used in coatings and certain alloys; and
Gold, used in circuit boards and electronic components.
Supply Chain
Our supply chain includes 563 different in-scope suppliers. Because of our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is challenging to identify actors upstream from our direct suppliers. There are many tiers of suppliers and sub-suppliers between the Company and the SORs that process the 3TG that is contained in each particular product manufactured or contracted to be manufactured by Sealed Air. Therefore, it is inherently difficult to determine the ultimate source of 3TG in the products we manufacture. As a result, we rely on our direct suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us - including sources of 3TG that are supplied to them from lower tier suppliers.
We have revised contract terms applicable to the majority of our suppliers with regard to 3TG. Those terms require suppliers to certify that, unless otherwise specified in writing, the products do not contain any 3TG, and further require that the suppliers respond to reasonable requests from the Company in connection with its compliance with Section 1502 of the Dodd-Frank Act.





 
Reasonable Country of Origin Inquiry
We conducted a RCOI reasonably designed to determine whether the 3TG in our products in the 2017 Report Year originated from the Covered Countries or are from recycled or scrap sources in accordance with the requirements of the Rule. The Covered Countries are the Democratic Republic of the Congo and its adjoining countries (Angola, Burundi, Republic of the Congo, Central African Republic, Rwanda, South Sudan, Tanzania, Uganda and Zambia). As part of its RCOI, and with the assistance of a third-party consultant, Assent Compliance, Inc. (“Assent”), the Company engaged its potential 3TG suppliers to collect information regarding the presence and sourcing of 3TG in its products. Suppliers were asked to complete and submit, within a certain time frame, the joint Electronic Industry Citizen Coalition (“EICC”) and Global e-Sustainability Initiative (“GeSI”) EICC-GeSI Conflict Minerals Reporting Template v. 5.01 or higher (“CMRT”). The CMRT is a standardized reporting template developed by the Responsible Minerals Initiative (“RMI”) that requests, among other things, information regarding country of origin of 3TG supplied to the Company and the SORs in the supply chain. Assent followed up with all unresponsive suppliers through a defined process via both automated emails and one-on-one emails, including offering assistance and further information to suppliers about the requirements of the Rule and the Company’s expectations. Based on the RCOI, Sealed Air determined that certain of our 3TG likely originated in the Covered Countries and did not come from 100% recycled or scrap sources. Accordingly, Sealed Air exercised due diligence on the source and chain of custody of such 3TG and is filing this Conflict Minerals Report for the 2017 Report Year.
Due Diligence
Design of Due Diligence
Sealed Air designed its due diligence process to conform with the due diligence framework in the Organization of Economic Co-operation and Development Due Diligence (“OECD”) Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition and related Supplements on Tin, Tantalum and Tungsten and on Gold (collectively the “OECD Guidance”).
Step One - Establish Strong Company Management Systems
Conflict Minerals Policy
We have adopted a Conflict Minerals policy, which is posted on our website at www.sealedair.com/investors.
Internal Team and Training
The Company has established an internal management team responsible for executing our Conflict Minerals due diligence process and reporting compliance. Our Conflict Minerals team is overseen by the General Counsel and Chief Supply Chain Officer and a team of subject matter experts from relevant functions such as quality, supply chain, operations, finance and legal. The team of subject matter experts is responsible for implementing our Conflict Minerals compliance strategy. Senior management is briefed about the results of our due diligence efforts on a regular basis.
We, in cooperation with Assent, have developed internal training programs to educate anyone within the Company that is a potential contact point for suppliers or other external parties regarding the Company’s Conflict Minerals compliance efforts. We intend to review our training programs at least annually to make sure they are continuously aligned with current regulations, our initiatives, and the tools we use.
Control Systems
As previously noted, the Company engaged Assent to facilitate supplier engagement and assist the Company in collecting, analyzing, verifying, and storing supplier-provided data and performing due diligence for the Conflict Minerals program. Data regarding the presence and sourcing of 3TG in materials, goods and components supplied to the Company was collected from suppliers utilizing the CMRT, a standardized reporting template developed by the RMI.
Our controls also include our Code of Business Conduct and Ethics, which outlines expected behaviors for all our employees.
Supplier Engagement
We rely on our direct suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us - including sources of 3TG that are supplied to them from lower tier suppliers.
 
In accordance with the OECD requirement to strengthen engagement with suppliers, we have, in cooperation with Assent, provided educational materials to suppliers on the Conflict Minerals regulations as well as relevant SEC reporting requirements





(as discussed further below). In addition, we have leveraged our existing communications framework, specifically through our procurement personnel, to encourage supplier interactions with Assent and to impress on our suppliers the importance of completing the Conflict Minerals surveys. It has also allowed for our supplier communications to be more focused and to ensure expectations are clear.
Additionally, as noted, the majority of our supplier contracts require suppliers to certify that, unless otherwise specified in writing, the products do not contain any 3TG, and further require that the suppliers respond to reasonable requests from the Company in connection with its compliance with Section 1502 of the Dodd-Frank Act.
This year, we put a strong emphasis on supplier education and training. To accomplish this, we utilized Assent’s Learning Management System, Assent University, and provided all in-scope suppliers access to their Conflict Minerals training course. This training is tracked and evaluated based on completion. All suppliers are encouraged to complete all modules within this course.
Grievance Mechanism
We have in place a grievance mechanism whereby employees and suppliers can report violations of the Company’s policies, including concerns with regard to Conflict Minerals. Employees and suppliers can raise concerns by emailing at contact.us@sealedair.com.
Records Maintenance
We have retained all relevant documentation from our RCOI and due diligence. Our policy related to relevant documentation of our Conflict Minerals compliance process requires that documentation be retained for a period of at least five years.
Step Two - Identify and Assess Risk in Our Supply Chain
Supplier Risk Assessment
Because of our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is challenging for us to identify suppliers other than our direct suppliers. After conducting a risk-based assessment of our direct suppliers, we identified over 563 different in-scope direct suppliers. We rely on suppliers whose materials or components contain 3TG to provide us with information about the source of 3TG contained in those materials or components. Our direct suppliers similarly rely upon information provided by their suppliers. Many of the largest suppliers either are SEC registrants and subject to the Rule or are suppliers to other SEC registrants that are subject to the Rule.
We calculate supplier risk based on the chances that a supplier provides 3TG that may originate from non-conflict free sources. The value of this risk is calculated based on the risk ratings of the SORs declared by that supplier on their CMRT. Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the supplier’s program are their answers to questions A, E, G and H on the Declaration tab of the CMRT:
Does the supplier have a policy in place that includes DRC conflict-free sourcing?
Has the supplier implemented due diligence measures for conflict-free sourcing?
Does the supplier verify due diligence information received from its suppliers?
Does the supplier’s verification process include corrective action management?
When a supplier meets these criteria, the supplier is deemed to have a strong program. When a supplier does not meet these criteria, the supplier is deemed to have a weak program.
As part of our risk management plan and to ensure suppliers understand our expectations, we have, through Assent, provided video and written training on Conflict Minerals and the CMRT. This training includes instructions on completing the form and one-on-one email and phone discussions with supplier personnel.

Supplier Surveys
Tracing materials back to their mine or location of origin is a complex aspect of responsible sourcing in our supply chain. We have determined that seeking information about 3TG SORs in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TG in our supply chain.





Our primary means of determining the origin of our 3TG for the 2017 Report Year was by conducting a supply chain survey with direct suppliers using the CMRT. This supply chain survey, and Sealed Air’s Conflict Minerals program as a whole, has been developed and implemented in cooperation with Assent.
Assent provided each supplier a copy of the EICC-GeSI reporting CMRT to complete for purposes of Conflict Minerals tracking. Assent and/or members of the Sealed Air supply chain team made at least three follow-up inquiries to each supplier that did not respond to our initial survey, either by phone or email or both. The Assent software platform automatically reviewed the responses against criteria developed to determine which required further engagement with our suppliers. These criteria included incomplete responses as well as inconsistencies within the data reported in the CMRT. Assent worked directly with those suppliers to provide revised responses.
Once surveys were returned, Assent reviewed and attempted to match each verified SOR identified in the completed surveys to available lists of SORs that have been validated as conflict free under internationally-recognized schemes such as the RMI Conflict-Free Smelter Program (“RMAP”). If a SOR was not validated by the RMAP, Assent either attempted to contact the SOR to gather more information about its sourcing practices or conducted Internet research to determine whether there are any additional publicly available sources of information regarding the SOR’s sourcing practices.
In accordance with OECD Guidelines, it is important to identify and assess risks associated with 3TGs in the supply chain. Risks were identified by assessing the due diligence practices of smelters and refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. Assent compared these facilities listed in the responses to the list of smelters and refiners maintained by the RMI to ensure that the facilities met the RMI definition of a 3TG processing facility that was operational during the 2017 calendar year.
In order to assess the risk that any of these smelters posed to our supply chain, Assent determined if the smelter had been audited against a standard in conformance with the OECD Guidance, such as the RMAP. We do not typically have a direct relationship with 3TG smelters and refiners and do not perform or direct audits of these entities within our supply chain. Smelters that have completed an RMAP audit are considered to be DRC-Conflict Free. In cases where the smelter’s due diligence practices have not been audited against the RMAP standard, a potential supply chain risk exists.
As of April 25, 2018, we have validated 321 smelters or refiners and are working to validate the additional smelter entries from the submitted CMRTs. Due to the provision of primarily supplier-level CMRTs, we cannot definitely determine their connection to the Covered Products.
Each facility that meets the RMI definition of a smelter or refiner of a 3TG mineral is assessed according to red flag indicators defined in the OECD Guidance. Assent uses 3 factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags.

Geographic proximity to the DRC and covered countries;
Responsible Minerals Assurance Process (RMAP) audit status;
Credible evidence of unethical or conflict sourcing.
Based on this criteria the following facilities have been identified with red-flag risks in their supply chain:
Tony Goetz NV - CID002587
African Gold Refinery Limited (AGR) - CID003185
Kaloti Precious Metals - CID002563
Universal Precious Metals Refining Zambia - CID002854
Fidelity Printers and Refiners - CID002515
Sudan Gold Refinery - CID002567
As part of our risk management plan under the OECD Guidance, when these facilities were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through Assent, submissions that include any of the above facilities immediately produce a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to Sealed Air, and escalating up to removal of these red flag smelters from their supply chain.
As per the OECD Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these red flags from the supply chain.  





Step Three - Design and Implement a Strategy to Respond to Risks
The Company maintains a risk management plan to respond to risks identified in the above-described risk assessment. The Company’s Conflict Minerals program is implemented, managed and monitored in accordance with this risk management plan.
The Company’s Conflict Minerals team provides updates to senior management of the Company in connection with the Conflict Minerals Program, including with regard to risk assessment and results of the annual due diligence process.
 
As described in our Conflict Minerals policy, we expect our suppliers to fully support our compliance efforts, including in connection with our due diligence efforts to trace the source and chain of custody of our 3TG. As part of our risk management plan, to ensure suppliers understand our expectations, we provided both video recorded training and documented instructions through Assent, and answered all questions that suppliers requiring further clarification presented to us.
Step Four - Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
Sealed Air does not have a direct relationship with 3TG SORs and, accordingly, we do not perform direct audits of these entities in our supply chain. Rather, Sealed Air relies on independent third-parties to audit and validate SORs.
Step Five - Report on Supply Chain Due Diligence
This Conflict Minerals Report is being filed with the SEC as an exhibit to our specialized disclosure report on Form SD and is available on our website at www.sealedair.com/investors.
Due Diligence Results
As a result of the due diligence efforts described above, we received completed CMRTs from 86% of our in-scope direct suppliers as of April 25, 2018. Appendix A lists the SORs identified by our direct suppliers that may have been used to process 3TGs necessary to the functionality or production of our products during 2017. For all responses that indicated a SOR, Assent compared the facilities listed to the list of SORs maintained by the RMI. If a supplier indicated that the facility was “Conflict-Free,” Assent confirmed that the name was listed by RMI as such. We have validated 321 SORs to date and we are working to validate the additional SOR entries from the submitted CMRTs. We have not listed in Appendix A any potential SORs that we have not been able to validate. Based on the SOR lists provided by suppliers via the CMRTs and publicly available information regarding the results of sourcing audits by the RMI, we have identified 257 Conflict-Free SORs. Appendix B includes an aggregated list of the countries of origin from which the reported facilities collectively source 3TGs, based on information provided by our suppliers.
The information that we received from a majority of our direct suppliers was at a company-wide level. Therefore, the SORs identified by our direct suppliers contained in Appendix A may include SORs that processed 3TGs that our direct suppliers supplied to their other customers rather than to us. As a result, we are unable to conclusively determine whether the SORs included in Appendix A were used to process the 3TGs necessary to the functionality or production of our products during 2017. Because of this uncertainty, we are also unable to conclusively determine whether each of the countries of origin listed in Appendix B was a country of origin of 3TGs in our products during 2017, and therefore are unable to conclusively determine the source and chain of custody of those 3TGs. In addition, the third-party audits conducted by the RMI, and the information that we receive from our direct suppliers may yield inaccurate or incomplete information. For example, the information received from our direct suppliers may be incomplete because they may not have received accurate and complete 3TG information from all of the suppliers in their own supply chain. We also do not have access to audit reports or detailed findings of the third-party audits conducted as part of the RMI Responsible Minerals Assurance Process and, as a result, are not responsible for the quality of these audits or the audit findings.
Risk Mitigation Efforts
We have taken, and intend to continue to take, the following steps to mitigate the risk that 3TG contained in products we manufacture or contract to manufacture benefit armed groups:
Track and add new suppliers as they enter Sealed Air’s supply chain to the Company’s Conflict Minerals program;
Engage with suppliers and direct them to training resources to attempt to increase the response rate and improve the content of the supplier survey responses;
Begin a targeted engagement plan with suppliers that do not reply or that reply with inaccurate or invalid responses; and





Encourage suppliers to use conflict-free SORs in the supply chain.
 
Forward-Looking Statements
This Conflict Minerals Report contains forward-looking statements that express certain beliefs, expectations or intentions, including with regard to our compliance efforts and expected actions in this regard. The words “expect,” “intend,” “plan,” “believe,” and “anticipate” and similar expressions may be used to identify these forward-looking statements. These statements are not guarantees of future actions or performance and are subject to various risks, uncertainties and assumptions. Undue reliance should be not be placed on these statements, which are only effective as of the date of this report. Sealed Air undertakes no obligation to publicly update or revise any forward-looking statement, other than as required by law.






Appendix A
Sealed Air Corporation
Conflict Minerals Report
For the Year Ended December 31, 2017
 
Metal
Standard Smelter Name
Smelter ID
RMI Audit Status
Gold
Abington Reldan Metals, LLC
CID002708
Not Enrolled
Gold
Advanced Chemical Company
CID000015
Conformant
Gold
African Gold Refinery
CID003185
Not Enrolled
Gold
Aida Chemical Industries Co., Ltd.
CID000019
Conformant
Gold
Al Etihad Gold LLC
CID002560
Conformant
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
CID000035
Conformant
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
CID000041
Conformant
Gold
AngloGold Ashanti Córrego do Sítio Mineração
CID000058
Conformant
Gold
Argor-Heraeus S.A.
CID000077
Conformant
Gold
Asahi Pretec Corp.
CID000082
Conformant
Gold
Asahi Refining Canada Ltd.
CID000924
Conformant
Gold
Asahi Refining USA Inc.
CID000920
Conformant
Gold
Asaka Riken Co., Ltd.
CID000090
Conformant
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
CID000103
Not Enrolled
Gold
AU Traders and Refiners
CID002850
Conformant
Gold
Aurubis AG
CID000113
Conformant
Gold
Bangalore Refinery
CID002863
Active
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
CID000128
Conformant
Gold
Boliden AB
CID000157
Conformant
Gold
C. Hafner GmbH + Co. KG
CID000176
Conformant
Gold
Caridad
CID000180
Not Enrolled
Gold
CCR Refinery - Glencore Canada Corporation
CID000185
Conformant
Gold
Cendres + Métaux S.A.
CID000189
Conformant
Gold
Chimet S.p.A.
CID000233
Conformant
Gold
Chugai Mining
CID000264
Not Enrolled
Gold
Daejin Indus Co., Ltd.
CID000328
Conformant
Gold
Daye Non-Ferrous Metals Mining Ltd.
CID000343
Not Enrolled
Gold
Degussa Sonne / Mond Goldhandel GmbH
CID002867
Not Enrolled
Gold
DODUCO Contacts and Refining GmbH
CID000362
Conformant
Gold
Dowa
CID000401
Conformant
Gold
DS PRETECH Co., Ltd.
CID003195
Active
Gold
DSC (Do Sung Corporation)
CID000359
Conformant
Gold
Eco-System Recycling Co., Ltd.
CID000425
Conformant
Gold
Elemetal Refining, LLC
CID001322
Not Enrolled
Gold
Emirates Gold DMCC
CID002561
Conformant
Gold
Fidelity Printers and Refiners Ltd.
CID002515
Not Enrolled
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
CID002852
Not Enrolled
Gold
Geib Refining Corporation
CID002459
Conformant
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CID002243
Conformant
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CID001909
Not Enrolled
Gold
Guangdong Jinding Gold Limited
CID002312
Not Enrolled
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CID000651
Not Enrolled
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CID000671
Not Enrolled





Gold
HeeSung
CID000689
Conformant
Gold
Heimerle + Meule GmbH
CID000694
Conformant
Gold
Heraeus Metals Hong Kong Ltd.
CID000707
Conformant
Gold
Heraeus Precious Metals GmbH & Co. KG
CID000711
Conformant
Gold
Hunan Chenzhou Mining Co., Ltd.
CID000767
Not Enrolled
Gold
Hwasung CJ Co., Ltd.
CID000778
Not Enrolled
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CID000801
Conformant
Gold
Ishifuku Metal Industry Co., Ltd.
CID000807
Conformant
Gold
Istanbul Gold Refinery
CID000814
Conformant
Gold
Italpreziosi
CID002765
Conformant
Gold
Japan Mint
CID000823
Conformant
Gold
Jiangxi Copper Co., Ltd.
CID000855
Conformant
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
CID000927
Conformant
Gold
JSC Uralelectromed
CID000929
Conformant
Gold
JX Nippon Mining & Metals Co., Ltd.
CID000937
Conformant
Gold
Kaloti Precious Metals
CID002563
Not Enrolled
Gold
Kazakhmys Smelting LLC
CID000956
Not Enrolled
Gold
Kazzinc
CID000957
Conformant
Gold
Kennecott Utah Copper LLC
CID000969
Conformant
Gold
KGHM Polska Miedz Spolka Akcyjna
CID002511
Active
Gold
Kojima Chemicals Co., Ltd.
CID000981
Conformant
Gold
Korea Zinc Co., Ltd.
CID002605
Conformant
Gold
Kyrgyzaltyn JSC
CID001029
Conformant
Gold
Kyshtym Copper-Electrolytic Plant ZAO
CID002865
Not Enrolled
Gold
L'azurde Company For Jewelry
CID001032
Not Enrolled
Gold
Lingbao Gold Co., Ltd.
CID001056
Not Enrolled
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CID001058
Not Enrolled
Gold
L'Orfebre S.A.
CID002762
Active
Gold
LS-NIKKO Copper Inc.
CID001078
Conformant
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CID001093
Not Enrolled
Gold
Marsam Metals
CID002606
Conformant
Gold
Materion
CID001113
Conformant
Gold
Matsuda Sangyo Co., Ltd.
CID001119
Conformant
Gold
Metalor Technologies (Hong Kong) Ltd.
CID001149
Conformant
Gold
Metalor Technologies (Singapore) Pte., Ltd.
CID001152
Conformant
Gold
Metalor Technologies (Suzhou) Ltd.
CID001147
Conformant
Gold
Metalor Technologies S.A.
CID001153
Conformant
Gold
Metalor USA Refining Corporation
CID001157
Conformant
Gold
Metalúrgica Met-Mex Peñoles S.A. De C.V.
CID001161
Conformant
Gold
Mitsubishi Materials Corporation
CID001188
Conformant
Gold
Mitsui Mining and Smelting Co., Ltd.
CID001193
Conformant
Gold
MMTC-PAMP India Pvt., Ltd.
CID002509
Conformant
Gold
Modeltech Sdn Bhd
CID002857
Active
Gold
Morris and Watson
CID002282
Not Enrolled
Gold
Morris and Watson Gold Coast
CID002866
Not Enrolled
Gold
Moscow Special Alloys Processing Plant
CID001204
Conformant
Gold
Nadir Metal Rafineri San. Ve Tic. A.ª.
CID001220
Conformant
Gold
Navoi Mining and Metallurgical Combinat
CID001236
Not Enrolled
Gold
NH Recytech Company
CID003189
Active
Gold
Nihon Material Co., Ltd.
CID001259
Conformant





Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
CID002779
Conformant
Gold
Ohura Precious Metal Industry Co., Ltd.
CID001325
Conformant
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
CID001326
Conformant
Gold
OJSC Novosibirsk Refinery
CID000493
Conformant
Gold
PAMP S.A.
CID001352
Conformant
Gold
Pease & Curren
CID002872
Not Enrolled
Gold
Penglai Penggang Gold Industry Co., Ltd.
CID001362
Not Enrolled
Gold
Planta Recuperadora de Metales SpA
CID002919
Conformant
Gold
Prioksky Plant of Non-Ferrous Metals
CID001386
Conformant
Gold
PT Aneka Tambang (Persero) Tbk
CID001397
Conformant
Gold
PX Précinox S.A.
CID001498
Conformant
Gold
Rand Refinery (Pty) Ltd.
CID001512
Conformant
Gold
Refinery of Seemine Gold Co., Ltd.
CID000522
Not Enrolled
Gold
Remondis Argentia B.V.
CID002582
Active
Gold
Republic Metals Corporation
CID002510
Conformant
Gold
Royal Canadian Mint
CID001534
Conformant
Gold
SAAMP
CID002761
Conformant
Gold
Sabin Metal Corp.
CID001546
Not Enrolled
Gold
Safimet S.p.A
CID002973
Conformant
Gold
SAFINA A.S.
CID002290
Active
Gold
Sai Refinery
CID002853
Not Enrolled
Gold
Samduck Precious Metals
CID001555
Conformant
Gold
SAMWON Metals Corp.
CID001562
Not Enrolled
Gold
SAXONIA Edelmetalle GmbH
CID002777
Conformant
Gold
Schone Edelmetaal B.V.
CID001573
Conformant
Gold
SEMPSA Joyería Platería S.A.
CID001585
Conformant
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CID001619
Not Enrolled
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CID001622
Conformant
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CID001736
Conformant
Gold
Singway Technology Co., Ltd.
CID002516
Conformant
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
CID001756
Conformant
Gold
Solar Applied Materials Technology Corp.
CID001761
Conformant
Gold
State Research Institute Center for Physical Sciences and Technology
CID003153
Not Enrolled
Gold
Sudan Gold Refinery
CID002567
Not Enrolled
Gold
Sumitomo Metal Mining Co., Ltd.
CID001798
Conformant
Gold
SungEel HiTech
CID002918
Conformant
Gold
T.C.A S.p.A
CID002580
Conformant
Gold
Tanaka Kikinzoku Kogyo K.K.
CID001875
Conformant
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CID001916
Conformant
Gold
Tokuriki Honten Co., Ltd.
CID001938
Conformant
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CID001947
Not Enrolled
Gold
Tony Goetz NV
CID002587
Not Enrolled
Gold
TOO Tau-Ken-Altyn
CID002615
Not Enrolled
Gold
Torecom
CID001955
Conformant
Gold
Umicore Brasil Ltda.
CID001977
Conformant
Gold
Umicore Precious Metals Thailand
CID002314
Conformant
Gold
Umicore S.A. Business Unit Precious Metals Refining
CID001980
Conformant
Gold
United Precious Metal Refining, Inc.
CID001993
Conformant
Gold
Universal Precious Metals Refining Zambia
CID002854
Not Enrolled





Gold
Valcambi S.A.
CID002003
Conformant
Gold
Western Australian Mint trading as The Perth Mint
CID002030
Conformant
Gold
WIELAND Edelmetalle GmbH
CID002778
Conformant
Gold
Yamamoto Precious Metal Co., Ltd.
CID002100
Conformant
Gold
Yokohama Metal Co., Ltd.
CID002129
Conformant
Gold
Yunnan Copper Industry Co., Ltd.
CID000197
Not Enrolled
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CID002224
Conformant
Tantalum
Asaka Riken Co., Ltd.
CID000092
Conformant
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CID000211
Conformant
Tantalum
D Block Metals, LLC
CID002504
Conformant
Tantalum
Duoluoshan
CID000410
Not Enrolled
Tantalum
Exotech Inc.
CID000456
Conformant
Tantalum
F&X Electro-Materials Ltd.
CID000460
Conformant
Tantalum
FIR Metals & Resource Ltd.
CID002505
Conformant
Tantalum
Global Advanced Metals Aizu
CID002558
Conformant
Tantalum
Global Advanced Metals Boyertown
CID002557
Conformant
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
CID000291
Conformant
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CID000616
Conformant
Tantalum
H.C. Starck Co., Ltd.
CID002544
Conformant
Tantalum
H.C. Starck Hermsdorf GmbH
CID002547
Conformant
Tantalum
H.C. Starck Inc.
CID002548
Conformant
Tantalum
H.C. Starck Ltd.
CID002549
Conformant
Tantalum
H.C. Starck Smelting GmbH & Co. KG
CID002550
Conformant
Tantalum
H.C. Starck Tantalum and Niobium GmbH
CID002545
Conformant
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CID002492
Conformant
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CID002512
Conformant
Tantalum
Jiangxi Tuohong New Raw Material
CID002842
Conformant
Tantalum
Jiujiang Janny New Material Co., Ltd.
CID003191
Conformant
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CID000914
Conformant
Tantalum
Jiujiang Tanbre Co., Ltd.
CID000917
Conformant
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CID002506
Conformant
Tantalum
KEMET Blue Metals
CID002539
Conformant
Tantalum
KEMET Blue Powder
CID002568
Conformant
Tantalum
King-Tan Tantalum Industry Ltd.
CID000973
Conformant
Tantalum
LSM Brasil S.A.
CID001076
Conformant
Tantalum
Metallurgical Products India Pvt., Ltd.
CID001163
Conformant
Tantalum
Mineracao Taboca S.A.
CID001175
Conformant
Tantalum
Mitsui Mining and Smelting Co., Ltd.
CID001192
Conformant
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CID001277
Conformant
Tantalum
NPM Silmet AS
CID001200
Conformant
Tantalum
Power Resources Ltd.
CID002847
Conformant
Tantalum
QuantumClean
CID001508
Conformant
Tantalum
Resind Industria e Comercio Ltda.
CID002707
Conformant
Tantalum
RFH Tantalum Smeltry Co., Ltd.
CID001522
Conformant
Tantalum
Solikamsk Magnesium Works OAO
CID001769
Conformant
Tantalum
Taki Chemicals
CID001869
Conformant
Tantalum
Telex Metals
CID001891
Conformant
Tantalum
Ulba Metallurgical Plant JSC
CID001969
Conformant
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CID002508
Conformant
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
CID002307
Conformant





Tin
Alpha
CID000292
Conformant
Tin
An Vinh Joint Stock Mineral Processing Company
CID002703
Not Enrolled
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CID000228
Conformant
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CID003190
Active
Tin
China Tin Group Co., Ltd.
CID001070
Conformant
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CID000278
Not Enrolled
Tin
CV Ayi Jaya
CID002570
Conformant
Tin
CV Dua Sekawan
CID002592
Conformant
Tin
CV Gita Pesona
CID000306
Conformant
Tin
CV Tiga Sekawan
CID002593
Conformant
Tin
CV United Smelting
CID000315
Conformant
Tin
CV Venus Inti Perkasa
CID002455
Conformant
Tin
Dowa
CID000402
Conformant
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
CID002572
Not Enrolled
Tin
EM Vinto
CID000438
Conformant
Tin
Estanho de Rondônia S.A.
CID000448
Not Enrolled
Tin
Fenix Metals
CID000468
Conformant
Tin
Gejiu Fengming Metallurgy Chemical Plant
CID002848
Conformant
Tin
Gejiu Jinye Mineral Company
CID002859
Conformant
Tin
Gejiu Kai Meng Industry and Trade LLC
CID000942
Conformant
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CID000538
Conformant
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CID001908
Conformant
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CID000555
Not Enrolled
Tin
Guangdong Hanhe Non-ferrous Metal Limited Company
CID003116
Conformant
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CID002849
Conformant
Tin
HuiChang Hill Tin Industry Co., Ltd.
CID002844
Conformant
Tin
Huichang Jinshunda Tin Co., Ltd.
CID000760
Conformant
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
CID000244
Conformant
Tin
Jiangxi New Nanshan Technology Ltd.
CID001231
Conformant
Tin
Magnu's Minerais Metais e Ligas Ltda.
CID002468
Conformant
Tin
Malaysia Smelting Corporation (MSC)
CID001105
Conformant
Tin
Melt Metais e Ligas S.A.
CID002500
Conformant
Tin
Metallic Resources, Inc.
CID001142
Conformant
Tin
Metallo Belgium N.V.
CID002773
Conformant
Tin
Metallo Spain S.L.U.
CID002774
Conformant
Tin
Mineracao Taboca S.A.
CID001173
Conformant
Tin
Minsur
CID001182
Conformant
Tin
Mitsubishi Materials Corporation
CID001191
Conformant
Tin
Modeltech Sdn Bhd
CID002858
Active
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
CID002573
Not Enrolled
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
CID001314
Conformant
Tin
O.M. Manufacturing Philippines, Inc.
CID002517
Conformant
Tin
Operaciones Metalurgical S.A.
CID001337
Conformant
Tin
Pongpipat Company Limited
CID003208
Not Enrolled
Tin
PT Aries Kencana Sejahtera
CID000309
Conformant
Tin
PT Artha Cipta Langgeng
CID001399
Conformant
Tin
PT ATD Makmur Mandiri Jaya
CID002503
Conformant
Tin
PT Babel Inti Perkasa
CID001402
Conformant
Tin
PT Bangka Prima Tin
CID002776
Conformant





Tin
PT Bangka Serumpun
CID003205
Conformant
Tin
PT Bangka Tin Industry
CID001419
Conformant
Tin
PT Belitung Industri Sejahtera
CID001421
Conformant
Tin
PT Bukit Timah
CID001428
Conformant
Tin
PT DS Jaya Abadi
CID001434
Conformant
Tin
PT Eunindo Usaha Mandiri
CID001438
Conformant
Tin
PT Inti Stania Prima
CID002530
Conformant
Tin
PT Karimun Mining
CID001448
Conformant
Tin
PT Kijang Jaya Mandiri
CID002829
Conformant
Tin
PT Lautan Harmonis Sejahtera
CID002870
Conformant
Tin
PT Menara Cipta Mulia
CID002835
Conformant
Tin
PT Mitra Stania Prima
CID001453
Conformant
Tin
PT O.M. Indonesia
CID002757
Conformant
Tin
PT Panca Mega Persada
CID001457
Conformant
Tin
PT Premium Tin Indonesia
CID000313
Conformant
Tin
PT Prima Timah Utama
CID001458
Conformant
Tin
PT Refined Bangka Tin
CID001460
Conformant
Tin
PT Sariwiguna Binasentosa
CID001463
Conformant
Tin
PT Stanindo Inti Perkasa
CID001468
Conformant
Tin
PT Sukses Inti Makmur
CID002816
Conformant
Tin
PT Sumber Jaya Indah
CID001471
Conformant
Tin
PT Timah (Persero) Tbk Kundur
CID001477
Conformant
Tin
PT Timah (Persero) Tbk Mentok
CID001482
Conformant
Tin
PT Tinindo Inter Nusa
CID001490
Conformant
Tin
PT Tommy Utama
CID001493
Conformant
Tin
Resind Industria e Comercio Ltda.
CID002706
Conformant
Tin
Rui Da Hung
CID001539
Conformant
Tin
Soft Metais Ltda.
CID001758
Conformant
Tin
Super Ligas
CID002756
Not Enrolled
Tin
Thaisarco
CID001898
Conformant
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
CID002574
Not Enrolled
Tin
White Solder Metalurgia e Mineração Ltda.
CID002036
Conformant
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CID002158
Conformant
Tin
Yunnan Tin Company Limited
CID002180
Conformant
Tungsten
A.L.M.T. TUNGSTEN Corp.
CID000004
Conformant
Tungsten
ACL Metais Eireli
CID002833
Conformant
Tungsten
Asia Tungsten Products Vietnam Ltd.
CID002502
Conformant
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CID002513
Conformant
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CID000258
Conformant
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CID000499
Conformant
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CID002645
Active
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CID000875
Conformant
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CID002315
Conformant
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CID002494
Conformant
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CID002536
Not Enrolled
Tungsten
Global Tungsten & Powders Corp.
CID000568
Conformant
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CID000218
Conformant
Tungsten
H.C. Starck Smelting GmbH & Co.KG
CID002542
Conformant
Tungsten
H.C. Starck Tungsten GmbH
CID002541
Conformant
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CID000766
Conformant





Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CID002579
Conformant
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CID000769
Conformant
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
CID003182
Conformant
Tungsten
Hydrometallurg, JSC
CID002649
Conformant
Tungsten
Japan New Metals Co., Ltd.
CID000825
Conformant
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CID002551
Conformant
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CID002647
Not Enrolled
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CID002321
Conformant
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CID002313
Not Enrolled
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CID002318
Conformant
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CID002317
Conformant
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
CID002535
Conformant
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CID002316
Conformant
Tungsten
Kennametal Fallon
CID000966
Conformant
Tungsten
Kennametal Huntsville
CID000105
Conformant
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CID002319
Conformant
Tungsten
Moliren Ltd
CID002845
Conformant
Tungsten
Niagara Refining LLC
CID002589
Conformant
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
CID002543
Conformant
Tungsten
Philippine Chuangxin Industrial Co., Inc.
CID002827
Conformant
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CID002815
Conformant
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
CID001889
Conformant
Tungsten
Unecha Refractory metals plant
CID002724
Conformant
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
CID002011
Conformant
Tungsten
Wolfram Bergbau und Hütten AG
CID002044
Conformant
Tungsten
Woltech Korea Co., Ltd.
CID002843
Conformant
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CID002320
Conformant
Tungsten
Xiamen Tungsten Co., Ltd.
CID002082
Conformant
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CID002830
Conformant
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CID002095
Conformant






Appendix B
Sealed Air Corporation
Conflict Minerals Report
For the Year Ended December 31, 2017

Argentina, Australia, Austria, Benin, Bolivia (Plurinational State of), Brazil, Burkina Faso, Burundi, Cambodia, Canada, Chile, China, Colombia, Congo, Democratic Republic of the, Ecuador, Eritrea, Ethiopia, France, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Japan, Kazakhstan, Laos, Madagascar, Malaysia, Mali, Mexico, Mongolia, Mozambique, Myanmar, Namibia, Nicaragua, Nigeria, Panama, Peru, Portugal, Russian Federation, Rwanda, Senegal, Sierra Leone, South Africa, Spain, Thailand, Togo, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Viet Nam, Zimbabwe