SONOCO PRODUCTS COMPANY
CONFLICT MINERALS POLICY
Introduction
The Securities and Exchange Commission (SEC), as required by the Dodd-Frank Act, requires publicly traded companies to annually conduct a good faith reasonable inquiry to determine whether any conflict minerals (columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives (tantalum, tin, and tungsten)) necessary to the functionality or production of products manufactured by the company or contracted to be manufactured by the company originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country, or are from recycled or scrap sources. The results of the inquiry are required to be disclosed annually in a report on Form SD, a Specialized Disclosure Report filed with the SEC.
Sonoco's Stance
Sonoco Products Company (collectively “Sonoco” or the “Company”) makes good faith efforts to ensure that any tantalum, tin, tungsten, and gold necessary to the production or functionality of their products are responsibly sourced. As some of Sonoco’s products may contain covered minerals, Sonoco conducts due diligence on its supply chain and reports on these efforts annually. Because Sonoco does not purchase these minerals directly from mines or smelters, the data underlying Sonoco’s reports relies on source information provided by Sonoco’s suppliers. Sonoco executes a program to carry out supply chain due diligence informed by guidance issued by the Organization for Economic Cooperation and Development (OECD), which the SEC has recognized as an appropriate due diligence framework for use in this context.
Our efforts are not intended altogether to ban the use of tantalum, tin, tungsten and gold that originate in conflict-affected and high-risk areas when they are sourced in accordance with existing international standards. We recognize that avoiding the sourcing of any of these minerals from these areas would cause a de facto embargo with serious adverse impact on the living conditions of local populations. However, we are committed to responsible sourcing of conflict free minerals, and we support efforts to eliminate the use of tantalum, tin, tungsten, and gold that are not conflict-free.
Our Supplier Requirements
Sonoco requires suppliers that provide us with tantalum, tin, tungsten or gold, or products containing these components, which are then incorporated into products we manufacture for sale, to submit information to us that allows us to trace the minerals back through the supply chain. We expect our suppliers to adopt policies and establish their own due diligence programs to ensure conflict free supply chains, and to provide us only with minerals or products that are conflict free. If we become aware of a supplier whose supply chain includes minerals that are not conflict free, we will take appropriate steps to remedy the situation in a timely manner, including reassessment of the supplier relationship. We expect our suppliers to take similar measures with their suppliers.
Conflict Minerals Policy and Disclosure
For more information, please review our Conflict Minerals Policy and Sonoco Form SD.