SILGAN HOLDINGS INC. |
(Exact name of Registrant as specified in its charter) |
Delaware | 000-22117 | 06-1269834 | |||
(State or other jurisdiction of incorporation) | (Commission File Number) | (I.R.S. Employer Identification No.) |
4 Landmark Square | ||
Stamford, Connecticut 06901 | ||
(Address of principal executive offices) |
Frank W. Hogan, III Senior Vice President, General Counsel and Secretary (203) 975-7110 | ||
(Name and telephone number, including area code, of the person to contact in connection with this report.) |
Item 1.01. | Conflict Minerals Disclosure and Report |
• | Steel and aluminum containers for human and pet food and general line products; |
• | Metal, composite (metal and plastic) and plastic closures for food and beverage products, and capping/sealing equipment and detection systems; and |
• | Custom design plastic containers for various consumer goods products. |
Item 1.02. | Exhibit |
Item 2.01. | Exhibits |
Date: June 1, 2015 | ||
By: | /s/ Frank W. Hogan, III | |
Name: | Frank W. Hogan, III | |
Title: | Senior Vice President, General | |
Counsel and Secretary | ||
I. | Design of Silgan’s Due Diligence Program |
II. | Due Diligence Measures Undertaken for 2014 Products |
• | Silgan established a Conflict Minerals Program Team composed of representatives from Silgan’s Legal, Regulatory Compliance and Purchasing departments across several of its business groups. Representatives from the Conflict Minerals Program Team coordinated, as necessary, and provided updates to Silgan senior management. |
• | During 2014, we implemented an internal approach to conflict minerals, which reflects our commitment to non-conflict sourcing, to guide our communications with suppliers and other interested parties regarding our approach to conflict minerals. |
• | We negotiated non-conflict sourcing provisions in our supplier contracts as they were initiated or renewed. |
• | Silgan maintained a company grievance mechanism through which employees or other individuals may report concerns to Silgan senior management. |
• | We maintained a system of supply chain transparency to identify the direct suppliers in our supply chain that may source necessary conflict minerals from the Covered Countries for use in materials for our products. This system included a process to identify suppliers of materials for our products and an outreach to these suppliers using a questionnaire (the “Questionnaire”) that we developed using the Conflict Minerals Reporting Template (“CMRT”) published by the Conflict- Free Sourcing Initiative (“CFSI”). |
• | Silgan used the Questionnaire to request information regarding the presence of conflict minerals in its products and whether such conflict minerals were sourced from the Covered Countries. |
• | Representatives from our Conflict Minerals Program Team sent the Questionnaire to our direct suppliers of materials for our products and collected responses from these suppliers. |
• | Silgan representatives then followed up with direct suppliers who failed to respond or whose responses were not reasonably complete. |
• | We reviewed the information collected through the completed Questionnaires to identify the direct suppliers who indicated that they potentially sourced conflict minerals from one of the Covered Countries. |
• | Silgan engaged in follow-up communications with direct suppliers who provided it with information indicating that such suppliers were engaged in an RCOI that had not been completed or who indicated they may be sourcing conflict minerals from the Covered Countries. In certain instances, we also engaged in follow-up communications with direct suppliers who indicated they had insufficient information to determine the origin of conflict minerals they sourced. |
• | In addition, for any direct suppliers whose responses raised questions regarding facilities that may have processed conflict minerals from the Covered Countries, the Questionnaire requested additional information regarding such suppliers’ conflict minerals policies and due diligence processes. |
• | With respect to such facilities as to which questions were raised, the Questionnaire requested information on the due diligence practices of these facilities, including whether the facilities were on the CFSI conflict-free smelter list, which supports the validation and certification of smelters as conflict free and is sponsored by the Electronic Industry Citizenship Coalition and the Global e-Sustainability Initiative. |
• | We reported the information we gathered through these steps to Silgan senior management. |
• | Silgan supports independent facility auditing programs through our internal approach to conflict minerals, which we formulated in 2013. This internal approach reflects our commitment to non-conflict sourcing and our expectation that our direct suppliers work to ensure conflict minerals contained in materials they supply to us are sourced from facilities that have been verified by an independent auditing program such as the Conflict-Free Smelter Program established by the CFSI. |
• | During the course of our due diligence measures and our review of the results, we also continued to review facility participation in these programs in greater detail. |
• | By filing our Form SD and this Conflict Minerals Report for the calendar year ended December 31, 2014, Silgan has completed its annual report on conflict minerals due diligence for such year. |
III. | Results of Due Diligence |
• | Capping/sealing equipment and detection systems. |
IV. | Efforts to Improve Silgan’s Due Diligence Program in 2015 |
• | Continue to engage with direct suppliers to ensure that their responses to our conflict minerals inquiries are reasonably complete. |
• | Continue to request that our direct suppliers use the Questionnaire based on CFSI’s CMRT to request conflict minerals information from their supply chains and provide conflict minerals information to Silgan. |
• | Encourage participation in an independent facility auditing program by any facilities identified to us by direct suppliers as potentially in the conflict minerals supply chain for our products. |