0000105770-14-000028.txt : 20140623 0000105770-14-000028.hdr.sgml : 20140623 20140602154443 ACCESSION NUMBER: 0000105770-14-000028 CONFORMED SUBMISSION TYPE: SD PUBLIC DOCUMENT COUNT: 2 13p-1 1.01 20131231 1.02 20131231 FILED AS OF DATE: 20140602 DATE AS OF CHANGE: 20140602 FILER: COMPANY DATA: COMPANY CONFORMED NAME: WEST PHARMACEUTICAL SERVICES INC CENTRAL INDEX KEY: 0000105770 STANDARD INDUSTRIAL CLASSIFICATION: FABRICATED RUBBER PRODUCTS, NEC [3060] IRS NUMBER: 231210010 STATE OF INCORPORATION: PA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: SD SEC ACT: 1934 Act SEC FILE NUMBER: 001-08036 FILM NUMBER: 14883888 BUSINESS ADDRESS: STREET 1: 101 GORDON DR STREET 2: P O BOX 645 CITY: LIONVILLE STATE: PA ZIP: 19341-0645 BUSINESS PHONE: 6105942900 MAIL ADDRESS: STREET 1: 101 GORDON DRIVE STREET 2: PO BOX 645 CITY: LIONVILLE STATE: PA ZIP: 19341-0645 FORMER COMPANY: FORMER CONFORMED NAME: WEST CO INC DATE OF NAME CHANGE: 19990405 SD 1 formsd_12312013.htm SD Form SD_12.31.2013


 

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
 

FORM SD
Specialized Disclosure Report


WEST PHARMACEUTICAL SERVICES, INC.

(Exact name of registrant as specified in its charter)

 
 
 
 
 
Pennsylvania
 
1-8036
 
23-1210010
(State or other jurisdiction
of incorporation or organization)
 
(Commission File Number)
 
(IRS Employer
Identification No.)
 
 
 
 
 
530 Herman O. West Drive, Exton, PA
 
 
 
19341-0645
(Address of principal executive offices)
 
 
 
(Zip Code)
 
William J. Federici, 610-594-2900
(Name and telephone number, including area code, of the person to contact in connection with this report.)

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:

þ
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2013.

 







Section 1    Conflict Minerals Disclosure

Item 1.01    Conflict Minerals Disclosure and Report

Conflict Minerals Disclosure

This Specialized Disclosure Report on Form SD of West Pharmaceutical Services, Inc. is for the period from January 1, 2013 to December 31, 2013. Unless the context indicates otherwise, “West,” “we,” “us,” and “our” refer to West Pharmaceutical Services, Inc. and its consolidated subsidiaries.

During 2013, certain of our operations manufactured, or contracted to manufacture, products for which 3TGs (as defined below) are necessary to the functionality or production (“Covered Products”). The term “3TGs” refers to columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, which are limited to tantalum, tin and tungsten. Accordingly, we have conducted a country of origin inquiry (“RCOI”) that was reasonably designed to determine whether any of the 3TGs in the Covered Products originated in the Democratic Republic of the Congo or an adjoining country (the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia or Angola), or were from recycled or scrap sources.

Information about our RCOI, as well as the steps we have taken to exercise due diligence on the source and chain of custody of any 3TGs in the Covered Products, is included in our Conflict Minerals Report, which is included as an exhibit to this Form SD. In addition, our Conflict Minerals Report is publicly available at: www.westpharma.com under “Investors-SEC Filings.”

Forward-Looking Statements

This Specialized Disclosure Report on Form SD, including the Conflict Minerals exhibit, contains forward-looking statements that are based upon management’s expectations and beliefs concerning future events impacting West. Certain matters contained herein concerning the future, including risk mitigation steps, constitute forward-looking statements and are based upon management’s expectations and beliefs. There can be no assurance that these future events will occur as anticipated. Forward-looking statements speak only as of the date they were made, and we undertake no obligation to publicly update them. For a description of certain factors that could cause our future results to differ materially from those expressed in any forward-looking statement, see Item 1A of our Annual Report on Form 10-K for the year ended December 31, 2013, entitled “Risk Factors.”

Inherent Limitation on Due Diligence Procedures

As a downstream purchaser of 3TGs, or components containing 3TGs, our diligence procedures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of such materials. Our diligence processes are based on the necessity of seeking data from our direct suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of 3TGs. We also rely, to a large extent, on information collected and provided by third parties. Such sources of information may yield inaccurate or incomplete information and may be subject to fraud.

Item 1.02     Exhibit

West has included its Conflict Minerals Report as Exhibit 1.02 to this Form SD.

Section 2     Exhibits

Item 2.01     Exhibits

Exhibit 1.02    Conflict Minerals Report as required by Items 1.01 and 1.02 of Form SD.








SIGNATURES


Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.



 
WEST PHARMACEUTICAL SERVICES, INC.
 
 
 
 
 
 
 
 
/s/ William J. Federici
 
 
William J. Federici
 
 
Senior Vice President and Chief Financial Officer
 
 
 
 
 
 
 
June 2, 2014
 
 







EXHIBIT INDEX

1.02
Conflict Minerals Report as required by Items 1.01 and 1.02 of Form SD



EX-1.02 2 exhibit102.htm EXHIBIT 1.02 Exhibit 1.02



Exhibit 1.02
West Pharmaceutical Services, Inc.
Conflict Minerals Report
for the Year Ended December 31, 2013

This Conflict Minerals Report (the “Report”) of West Pharmaceutical Services, Inc. has been prepared for the period from January 1, 2013 to December 31, 2013. Unless the context indicates otherwise, “West,” “we,” “us,” and “our” refer to West Pharmaceutical Services, Inc. and its consolidated subsidiaries.

During 2013, certain of our operations manufactured, or contracted to manufacture, products for which 3TGs (as defined below) are necessary to the functionality or production (“Covered Products”). The term “3TGs” refers to columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, which are limited to tantalum, tin and tungsten. These Covered Products are manufactured or contracted for manufacture by our Pharmaceutical Delivery Systems segment. Certain electronic components used in our SmartDose product contain 3TGs.

We have developed a conflict minerals compliance program reasonably designed to identify whether the 3TGs in the Covered Products originated in the Democratic Republic of the Congo or an adjoining country (the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia or Angola) (the “Covered Countries”), or whether any of the 3TGs in the Covered Products are from recycled or scrap sources. Our conflict minerals compliance program is overseen by our procurement group, and senior management has been informed about the process, progress and results.

Description of West’s Reasonable Country of Origin Inquiry (RCOI)

We have conducted a country of origin inquiry (“RCOI”) that was reasonably designed to determine whether any of the 3TGs in the Covered Products originated in a Covered Country or whether any of the 3TGs in the Covered Products were from recycled or scrap sources.

In conducting our RCOI, first, we identified suppliers of components for West products. Second, we conducted a supply chain survey of our direct suppliers to provide information on the origin of any 3TGs contained in materials supplied to us. Third, after receiving the responses, if any included 3TGs, we reviewed the materials supplied, to determine if the components or materials were necessary to the functionality or production of the West product.
The supply chain survey was implemented and administered by our procurement group. The survey employed a modified form of the template developed by the Electronic Industry Citizenship Coalition® and The Global e-Sustainability Initiative, known as the CFSI Reporting Template (the “Template”). The Template was developed to facilitate general disclosures and information regarding the materials used by the supplier and the source and chain of custody of those materials. It included questions regarding the supplier’s conflict-free minerals policy, the engagement process with its direct suppliers, and identification of any conflict minerals used by the supplier and the source and chain of custody of those minerals.

As of June 1, 2014, approximately 95% of our direct suppliers surveyed have responded, with responses received from a significant majority of the suppliers believed by us to be the most likely to include 3TGs within the materials contained in the Covered Products.

None of the surveys received as of June 1, 2014 from suppliers indicated that the suppliers source 3TGs from the Covered Countries.







Due Diligence Process

Following our RCOI, we conducted a due diligence review of the source and chain of custody of the 3TGs contained in the Covered Products. Our due diligence measures were designed to conform in all material respects with the framework in the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Guidance”) and the related Supplements for gold and for tin, tantalum and tungsten.

As part of this due diligence review, we reviewed the suppliers’ responses to the surveys discussed above against criteria developed to determine which responses required further engagement with the suppliers. These criteria included untimely or incomplete responses, as well as inconsistencies within the data reported in the Template, whether supplier was a U.S. publicly-held company and size of the supplier’s business. We worked directly with these suppliers to obtain additional information and, as appropriate, updated responses.

We believe that the inquiries and investigations described above represent a reasonable effort to determine the mines or locations of origin of the 3TGs in our Covered Products.

DRC Conflict Undeterminable

We conducted an analysis of our products and found that 3TG can be found in our products. Therefore, the products that we manufacture or contract to manufacture are subject to the reporting obligations of Rule 13p-1. Despite having conducted a good faith RCOI, we have concluded that our supply chain remains “DRC Conflict Undeterminable.” We reached this conclusion because we have been unable to determine the origin of all of the 3TG in our Covered Products.

Due to the breadth and complexity of our products and respective supply chain, it will take time for many of our suppliers to verify the origin of all of the minerals. Using our supply chain diligence processes, driving accountability within the supply chain by leveraging the industry standard CFSI/CFS program and continuing our outreach efforts, we hope to further develop transparency into our supply chain.

Risk Mitigation

We have taken or intend to take the following steps to further mitigate the risk that the 3TGs in the Covered Products could benefit armed groups in the Covered Countries:

Implement a supplier screening program that requires suppliers to provide information regarding 3TGs.

Develop and implement a formal Conflict Minerals policy that will be provided to our suppliers.

Encourage suppliers to establish procedures to identify the origin of 3TGs.

Continue and further improve our direct supplier surveys and due diligence process.