UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549  

FORM SD

Specialized Disclosure Report

 

SEALED AIR CORPORATION

(Exact Name of Registrant as Specified in its Charter)

Delaware			1-12139			65-0654331
(State or Other Jurisdiction of Incorporation)			(Commission File Number)			(IRS Employer Identification No.)

 

2415 Cascade Pointe Boulevard Charlotte, North Carolina			28208
(Address of Principal Executive Offices)			(Zip Code)

Angel S. Willis

Vice President, General Counsel & Secretary

980-221-3235

(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:

☒ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2019.

 

 

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Section 1 - Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

In accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Conflict Minerals Rule”), Sealed Air Corporation (“Sealed Air” or the “Company”) is filing this Form SD to disclose information relating to the Company’s use and sourcing of columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin and tungsten (“3TG” or “Conflict Minerals”).

The Company has determined that during the reporting period January 1, 2019 to December 31, 2019, certain of the products the Company manufactures or contracts to manufacture contained 3TG that was necessary to the functionality or production of those products. Sealed Air conducted a reasonable country of origin inquiry (“RCOI”) designed to determine whether any of the 3TG originated in the Democratic Republic of the Congo or an adjoining country (together, a “Covered Country”) and whether any of the 3TG originated from recycled or scrap sources. Based on this RCOI, Sealed Air determined that certain of the 3TG likely originated in the Covered Countries and did not originate from recycled or scrap sources. Accordingly, Sealed Air exercised due diligence on the source and chain of custody of such 3TG and has filed a Conflict Minerals Report for calendar year 2019 (the “2019 Conflict Minerals Report”). The Company’s 2019 Conflict Minerals Report is attached hereto as Exhibit 1.01 and is publicly available at ir.sealedair.com/reports-filings/sec-filings.

Item 1.02 Exhibit

The Company’s 2019 Conflict Minerals Report, as required by Item 1.02, is attached as Exhibit 1.01 to this Form SD.

Section 2 - Exhibits

Item 2.01 Exhibits

Exhibit 1.01 - Conflict Minerals Report for the reporting period January 1 to December 31, 2019.

 

 

SIGNATURE

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 duly authorized undersigned.

 

Sealed Air Corporation

By:

/s/ Angel S. Willis

Angel S. Willis

Vice President, General Counsel & Secretary

Dated: May 28, 2020

Exhibit 1.01

Sealed Air Corporation

Conflict Minerals Report

For the Year Ended December 31, 2019

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, 2019. 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 2019 (the “2019 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 leading global provider of packaging solutions for the food, e-Commerce, electronics and industrial markets. The Company serves an array of end markets including food and beverage processing, food service, retail, commercial and consumer applications. Our focus is on achieving quality profitable growth and increased earnings power through partnering with our customers to provide innovative, sustainable packaging solutions that solve their most complex packaging problems and create differential value for them.

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 2019. Through a screening process, the Company determined that, to the best of our knowledge, customer equipment and other select products of the Company, 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 325 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

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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 2019 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. 5.12 or higher (“CMRT”) via the Assent Compliance Manager (ACM), a SaaS platform provided by Assent that enables its users to complete and track supplier communications as well as allow suppliers to upload completed CMRTs directly to the platform for assessment and management. 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 training and education to guide suppliers on best practices of this template, as well as 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 2019 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”). The OECD Guidance identifies five steps for due diligence that should be implemented and provides guidance as to how to achieve each step. We developed our due diligence process to address each of these five steps, namely:

1.Establishing strong company management systems regarding conflict minerals;

2.Identifying and assessing risks in our supply chain;

3.Designing and implementing a strategy to respond to identified risks in our supply chain;

4.Utilizing independent third-party audits of supply chain diligence; and

5.Publicly reporting on our supply chain due diligence.

Step One - Establish Strong Company Management Systems

Conflict Minerals Policy

We have adopted a Conflict Minerals policy, which is posted on our website at sealedair.com/company/suppliers.

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 the Chief Manufacturing & 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.

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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.

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. All of the information and findings from this process is stored in a database that can be audited by internal or external parties.

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 325 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

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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 2019 Report Year was by conducting a supply chain survey to our 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 2019 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 May 11, 2020, we have validated 298 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 numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:

•Geographic proximity to the DRC and covered countries;

•Known mineral source country of origin;

•Responsible Minerals Assurance Process (RMAP) audit status;

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•Credible evidence of unethical or conflict sourcing; and

•Peer Assessments conducted by credible third-party sources.

Based on these 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

•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. In addition, suppliers are guided to the Assent University learning platform to engage in educational materials on mitigating the risk of smelters or refiners on 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 ir.sealedair.com/reports-filings/sec-filings.

Due Diligence Results

As a result of the due diligence efforts described above, we received completed CMRTs from 54% of our in-scope direct suppliers as of May 11, 2020. 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 2019. 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 298 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 235 RMAP Conformant SORs. Appendix B includes

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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 2019. 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 2019, 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.

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Appendix A

Sealed Air Corporation

Conflict Minerals Report

For the Year Ended December 31, 2019

 

Metal			Standard Smelter Name			Smelter Facility Location
Gold			8853 S.p.A.			ITALY
Gold			Abington Reldan Metals, LLC			UNITED STATES OF AMERICA
Gold			Advanced Chemical Company			UNITED STATES OF AMERICA
Gold			African Gold Refinery			UGANDA
Gold			Aida Chemical Industries Co., Ltd.			JAPAN
Gold			Al Etihad Gold Refinery DMCC			UNITED ARAB EMIRATES
Gold			Allgemeine Gold-und Silberscheideanstalt A.G.			GERMANY
Gold			Almalyk Mining and Metallurgical Complex (AMMC)			UZBEKISTAN
Gold			AngloGold Ashanti Corrego do Sitio Mineracao			BRAZIL
Gold			Argor-Heraeus S.A.			SWITZERLAND
Gold			Asahi Pretec Corp.			JAPAN
Gold			Asahi Refining Canada Ltd.			CANADA
Gold			Asahi Refining USA Inc.			UNITED STATES OF AMERICA
Gold			Asaka Riken Co., Ltd.			JAPAN
Gold			Atasay Kuyumculuk Sanayi Ve Ticaret A.S.			TURKEY
Gold			AU Traders and Refiners			SOUTH AFRICA
Gold			Aurubis AG			GERMANY
Gold			Bangalore Refinery			INDIA
Gold			Bangko Sentral ng Pilipinas (Central Bank of the Philippines)			PHILIPPINES
Gold			Boliden AB			SWEDEN
Gold			C. Hafner GmbH + Co. KG			GERMANY
Gold			Caridad			MEXICO
Gold			CCR Refinery - Glencore Canada Corporation			CANADA
Gold			Cendres + Metaux S.A.			SWITZERLAND
Gold			CGR Metalloys Pvt Ltd.			INDIA
Gold			Chimet S.p.A.			ITALY
Gold			Chugai Mining			JAPAN
Gold			Daye Non-Ferrous Metals Mining Ltd.			CHINA
Gold			Degussa Sonne / Mond Goldhandel GmbH			GERMANY
Gold			Dijllah Gold Refinery FZC			UNITED ARAB EMIRATES
Gold			DODUCO Contacts and Refining GmbH			GERMANY
Gold			Dowa			JAPAN
Gold			DS PRETECH Co., Ltd.			KOREA, REPUBLIC OF
Gold			DSC (Do Sung Corporation)			KOREA, REPUBLIC OF
Gold			Eco-System Recycling Co., Ltd. East Plant			JAPAN
Gold			Eco-System Recycling Co., Ltd. North Plant			JAPAN
Gold			Eco-System Recycling Co., Ltd. West Plant			JAPAN
Gold			Emirates Gold DMCC			UNITED ARAB EMIRATES
Gold			Fidelity Printers and Refiners Ltd.			ZIMBABWE
Gold			Fujairah Gold FZC			UNITED ARAB EMIRATES
Gold			GCC Gujrat Gold Centre Pvt. Ltd.			INDIA
Gold			Geib Refining Corporation			UNITED STATES OF AMERICA
Gold			Gold Refinery of Zijin Mining Group Co., Ltd.			CHINA

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Gold			Great Wall Precious Metals Co., Ltd. of CBPM			CHINA
Gold			Guangdong Jinding Gold Limited			CHINA
Gold			Guoda Safina High-Tech Environmental Refinery Co., Ltd.			CHINA
Gold			Hangzhou Fuchunjiang Smelting Co., Ltd.			CHINA
Gold			Heimerle + Meule GmbH			GERMANY
Gold			Heraeus Metals Hong Kong Ltd.			CHINA
Gold			Heraeus Precious Metals GmbH & Co. KG			GERMANY
Gold			Hunan Chenzhou Mining Co., Ltd.			CHINA
Gold			Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.			CHINA
Gold			HwaSeong CJ CO., LTD.			KOREA, REPUBLIC OF
Gold			Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.			CHINA
Gold			International Precious Metal Refiners			UNITED ARAB EMIRATES
Gold			Ishifuku Metal Industry Co., Ltd.			JAPAN
Gold			Istanbul Gold Refinery			TURKEY
Gold			Italpreziosi			ITALY
Gold			Japan Mint			JAPAN
Gold			Jiangxi Copper Co., Ltd.			CHINA
Gold			JSC Ekaterinburg Non-Ferrous Metal Processing Plant			RUSSIAN FEDERATION
Gold			JSC Uralelectromed			RUSSIAN FEDERATION
Gold			JX Nippon Mining & Metals Co., Ltd.			JAPAN
Gold			Kaloti Precious Metals			UNITED ARAB EMIRATES
Gold			Kazakhmys Smelting LLC			KAZAKHSTAN
Gold			Kazzinc			KAZAKHSTAN
Gold			Kennecott Utah Copper LLC			UNITED STATES OF AMERICA
Gold			KGHM Polska Miedz Spolka Akcyjna			POLAND
Gold			Kojima Chemicals Co., Ltd.			JAPAN
Gold			Korea Zinc Co., Ltd.			KOREA, REPUBLIC OF
Gold			Kyrgyzaltyn JSC			KYRGYZSTAN
Gold			Kyshtym Copper-Electrolytic Plant ZAO			RUSSIAN FEDERATION
Gold			L'azurde Company For Jewelry			SAUDI ARABIA
Gold			Lingbao Gold Co., Ltd.			CHINA
Gold			Lingbao Jinyuan Tonghui Refinery Co., Ltd.			CHINA
Gold			L'Orfebre S.A.			ANDORRA
Gold			LS-NIKKO Copper Inc.			KOREA, REPUBLIC OF
Gold			LT Metal Ltd.			KOREA, REPUBLIC OF
Gold			Luoyang Zijin Yinhui Gold Refinery Co., Ltd.			CHINA
Gold			Marsam Metals			BRAZIL
Gold			Materion			UNITED STATES OF AMERICA
Gold			Matsuda Sangyo Co., Ltd.			JAPAN
Gold			Metalor Technologies (Hong Kong) Ltd.			CHINA
Gold			Metalor Technologies (Singapore) Pte., Ltd.			SINGAPORE
Gold			Metalor Technologies (Suzhou) Ltd.			CHINA
Gold			Metalor Technologies S.A.			SWITZERLAND
Gold			Metalor USA Refining Corporation			UNITED STATES OF AMERICA
Gold			Metalurgica Met-Mex Penoles S.A. De C.V.			MEXICO
Gold			Mitsubishi Materials Corporation			JAPAN
Gold			Mitsui Mining and Smelting Co., Ltd.			JAPAN
Gold			MMTC-PAMP India Pvt., Ltd.			INDIA
Gold			Modeltech Sdn Bhd			MALAYSIA

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Gold			Morris and Watson			NEW ZEALAND
Gold			Moscow Special Alloys Processing Plant			RUSSIAN FEDERATION
Gold			Nadir Metal Rafineri San. Ve Tic. A.S.			TURKEY
Gold			Navoi Mining and Metallurgical Combinat			UZBEKISTAN
Gold			NH Recytech Company			KOREA, REPUBLIC OF
Gold			Nihon Material Co., Ltd.			JAPAN
Gold			Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH			AUSTRIA
Gold			Ohura Precious Metal Industry Co., Ltd.			JAPAN
Gold			OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)			RUSSIAN FEDERATION
Gold			OJSC Novosibirsk Refinery			RUSSIAN FEDERATION
Gold			PAMP S.A.			SWITZERLAND
Gold			Pease & Curren			UNITED STATES OF AMERICA
Gold			Penglai Penggang Gold Industry Co., Ltd.			CHINA
Gold			Planta Recuperadora de Metales SpA			CHILE
Gold			Prioksky Plant of Non-Ferrous Metals			RUSSIAN FEDERATION
Gold			PT Aneka Tambang (Persero) Tbk			INDONESIA
Gold			PX Precinox S.A.			SWITZERLAND
Gold			QG Refining, LLC			UNITED STATES OF AMERICA
Gold			Rand Refinery (Pty) Ltd.			SOUTH AFRICA
Gold			Refinery of Seemine Gold Co., Ltd.			CHINA
Gold			REMONDIS PMR B.V.			NETHERLANDS
Gold			Royal Canadian Mint			CANADA
Gold			SAAMP			FRANCE
Gold			Sabin Metal Corp.			UNITED STATES OF AMERICA
Gold			Safimet S.p.A			ITALY
Gold			SAFINA A.S.			CZECH REPUBLIC
Gold			Sai Refinery			INDIA
Gold			Samduck Precious Metals			KOREA, REPUBLIC OF
Gold			Samwon Metals Corp.			KOREA, REPUBLIC OF
Gold			SAXONIA Edelmetalle GmbH			GERMANY
Gold			SEMPSA Joyeria Plateria S.A.			SPAIN
Gold			Shandong Humon Smelting Co., Ltd.			CHINA
Gold			Shandong Tiancheng Biological Gold Industrial Co., Ltd.			CHINA
Gold			Shandong Zhaojin Gold & Silver Refinery Co., Ltd.			CHINA
Gold			Sichuan Tianze Precious Metals Co., Ltd.			CHINA
Gold			Singway Technology Co., Ltd.			TAIWAN, PROVINCE OF CHINA
Gold			SOE Shyolkovsky Factory of Secondary Precious Metals			RUSSIAN FEDERATION
Gold			Solar Applied Materials Technology Corp.			TAIWAN, PROVINCE OF CHINA
Gold			Sovereign Metals			INDIA
Gold			State Research Institute Center for Physical Sciences and Technology			LITHUANIA
Gold			Sudan Gold Refinery			SUDAN
Gold			Sumitomo Metal Mining Co., Ltd.			JAPAN
Gold			SungEel HiMetal Co., Ltd.			KOREA, REPUBLIC OF
Gold			T.C.A S.p.A			ITALY
Gold			Tanaka Kikinzoku Kogyo K.K.			JAPAN
Gold			The Refinery of Shandong Gold Mining Co., Ltd.			CHINA
Gold			Tokuriki Honten Co., Ltd.			JAPAN
Gold			Tongling Nonferrous Metals Group Co., Ltd.			CHINA

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Gold			Tony Goetz NV			BELGIUM
Gold			TOO Tau-Ken-Altyn			KAZAKHSTAN
Gold			Torecom			KOREA, REPUBLIC OF
Gold			Umicore Brasil Ltda.			BRAZIL
Gold			Umicore Precious Metals Thailand			THAILAND
Gold			Umicore S.A. Business Unit Precious Metals Refining			BELGIUM
Gold			United Precious Metal Refining, Inc.			UNITED STATES OF AMERICA
Gold			Valcambi S.A.			SWITZERLAND
Gold			Western Australian Mint (T/a The Perth Mint)			AUSTRALIA
Gold			WIELAND Edelmetalle GmbH			GERMANY
Gold			Yamakin Co., Ltd.			JAPAN
Gold			Yokohama Metal Co., Ltd.			JAPAN
Gold			Yunnan Copper Industry Co., Ltd.			CHINA
Gold			Zhongyuan Gold Smelter of Zhongjin Gold Corporation			CHINA
Tantalum			Asaka Riken Co., Ltd.			JAPAN
Tantalum			Changsha South Tantalum Niobium Co., Ltd.			CHINA
Tantalum			CP Metals Inc.			UNITED STATES OF AMERICA
Tantalum			D Block Metals, LLC			UNITED STATES OF AMERICA
Tantalum			Exotech Inc.			UNITED STATES OF AMERICA
Tantalum			F&X Electro-Materials Ltd.			CHINA
Tantalum			FIR Metals & Resource Ltd.			CHINA
Tantalum			Global Advanced Metals Aizu			JAPAN
Tantalum			Global Advanced Metals Boyertown			UNITED STATES OF AMERICA
Tantalum			Guangdong Zhiyuan New Material Co., Ltd.			CHINA
Tantalum			H.C. Starck Co., Ltd.			THAILAND
Tantalum			H.C. Starck Hermsdorf GmbH			GERMANY
Tantalum			H.C. Starck Inc.			UNITED STATES OF AMERICA
Tantalum			H.C. Starck Ltd.			JAPAN
Tantalum			H.C. Starck Smelting GmbH & Co. KG			GERMANY
Tantalum			H.C. Starck Tantalum and Niobium GmbH			GERMANY
Tantalum			Hengyang King Xing Lifeng New Materials Co., Ltd.			CHINA
Tantalum			Jiangxi Dinghai Tantalum & Niobium Co., Ltd.			CHINA
Tantalum			Jiangxi Tuohong New Raw Material			CHINA
Tantalum			JiuJiang JinXin Nonferrous Metals Co., Ltd.			CHINA
Tantalum			Jiujiang Tanbre Co., Ltd.			CHINA
Tantalum			Jiujiang Zhongao Tantalum & Niobium Co., Ltd.			CHINA
Tantalum			KEMET Blue Metals			MEXICO
Tantalum			LSM Brasil S.A.			BRAZIL
Tantalum			Metallurgical Products India Pvt., Ltd.			INDIA
Tantalum			Mineracao Taboca S.A.			BRAZIL
Tantalum			Mitsui Mining and Smelting Co., Ltd.			JAPAN
Tantalum			Ningxia Orient Tantalum Industry Co., Ltd.			CHINA
Tantalum			NPM Silmet AS			ESTONIA
Tantalum			PRG Dooel			NORTH MACEDONIA, REPUBLIC OF
Tantalum			QuantumClean			UNITED STATES OF AMERICA
Tantalum			Resind Industria e Comercio Ltda.			BRAZIL
Tantalum			Solikamsk Magnesium Works OAO			RUSSIAN FEDERATION
Tantalum			Taki Chemical Co., Ltd.			JAPAN

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Tantalum			Telex Metals			UNITED STATES OF AMERICA
Tantalum			Ulba Metallurgical Plant JSC			KAZAKHSTAN
Tantalum			XinXing HaoRong Electronic Material Co., Ltd.			CHINA
Tantalum			Yanling Jincheng Tantalum & Niobium Co., Ltd.			CHINA
Tin			Alpha			UNITED STATES OF AMERICA
Tin			An Vinh Joint Stock Mineral Processing Company			VIET NAM
Tin			Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.			CHINA
Tin			Chifeng Dajingzi Tin Industry Co., Ltd.			CHINA
Tin			China Tin Group Co., Ltd.			CHINA
Tin			Dongguan CiEXPO Environmental Engineering Co., Ltd.			CHINA
Tin			Dowa			JAPAN
Tin			Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company			VIET NAM
Tin			EM Vinto			BOLIVIA (PLURINATIONAL STATE OF)
Tin			Estanho de Rondonia S.A.			BRAZIL
Tin			Fenix Metals			POLAND
Tin			Gejiu City Fuxiang Industry and Trade Co., Ltd.			CHINA
Tin			Gejiu Kai Meng Industry and Trade LLC			CHINA
Tin			Gejiu Non-Ferrous Metal Processing Co., Ltd.			CHINA
Tin			Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.			CHINA
Tin			Gejiu Zili Mining And Metallurgy Co., Ltd.			CHINA
Tin			Guangdong Hanhe Non-Ferrous Metal Co., Ltd.			CHINA
Tin			Guanyang Guida Nonferrous Metal Smelting Plant			CHINA
Tin			HuiChang Hill Tin Industry Co., Ltd.			CHINA
Tin			Huichang Jinshunda Tin Co., Ltd.			CHINA
Tin			Jiangxi New Nanshan Technology Ltd.			CHINA
Tin			Luna Smelter, Ltd.			RWANDA
Tin			Ma'anshan Weitai Tin Co., Ltd.			CHINA
Tin			Magnu's Minerais Metais e Ligas Ltda.			BRAZIL
Tin			Malaysia Smelting Corporation (MSC)			MALAYSIA
Tin			Melt Metais e Ligas S.A.			BRAZIL
Tin			Metallic Resources, Inc.			UNITED STATES OF AMERICA
Tin			Metallo Belgium N.V.			BELGIUM
Tin			Metallo Spain S.L.U.			SPAIN
Tin			Mineracao Taboca S.A.			BRAZIL
Tin			Minsur			PERU
Tin			Mitsubishi Materials Corporation			JAPAN
Tin			Modeltech Sdn Bhd			MALAYSIA
Tin			Nghe Tinh Non-Ferrous Metals Joint Stock Company			VIET NAM
Tin			O.M. Manufacturing (Thailand) Co., Ltd.			THAILAND
Tin			O.M. Manufacturing Philippines, Inc.			PHILIPPINES
Tin			Operaciones Metalurgicas S.A.			BOLIVIA (PLURINATIONAL STATE OF)
Tin			Pongpipat Company Limited			MYANMAR
Tin			Precious Minerals and Smelting Limited			INDIA
Tin			PT Artha Cipta Langgeng			INDONESIA
Tin			PT ATD Makmur Mandiri Jaya			INDONESIA
Tin			PT Menara Cipta Mulia			INDONESIA
Tin			PT Mitra Stania Prima			INDONESIA

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Tin			PT Refined Bangka Tin			INDONESIA
Tin			PT Timah Tbk Kundur			INDONESIA
Tin			PT Timah Tbk Mentok			INDONESIA
Tin			Resind Industria e Comercio Ltda.			BRAZIL
Tin			Rui Da Hung			TAIWAN, PROVINCE OF CHINA
Tin			Soft Metais Ltda.			BRAZIL
Tin			Super Ligas			BRAZIL
Tin			Thai Nguyen Mining and Metallurgy Co., Ltd.			VIET NAM
Tin			Thaisarco			THAILAND
Tin			Tin Technology & Refining			UNITED STATES OF AMERICA
Tin			Tuyen Quang Non-Ferrous Metals Joint Stock Company			VIET NAM
Tin			White Solder Metalurgia e Mineracao Ltda.			BRAZIL
Tin			Yunnan Chengfeng Non-ferrous Metals Co., Ltd.			CHINA
Tin			Yunnan Tin Company Limited			CHINA
Tin			Yunnan Yunfan Non-ferrous Metals Co., Ltd.			CHINA
Tungsten			A.L.M.T. Corp.			JAPAN
Tungsten			ACL Metais Eireli			BRAZIL
Tungsten			Asia Tungsten Products Vietnam Ltd.			VIET NAM
Tungsten			Chenzhou Diamond Tungsten Products Co., Ltd.			CHINA
Tungsten			China Molybdenum Co., Ltd.			CHINA
Tungsten			Chongyi Zhangyuan Tungsten Co., Ltd.			CHINA
Tungsten			CNMC (Guangxi) PGMA Co., Ltd.			CHINA
Tungsten			Fujian Ganmin RareMetal Co., Ltd.			CHINA
Tungsten			Fujian Jinxin Tungsten Co., Ltd.			CHINA
Tungsten			Ganzhou Haichuang Tungsten Co., Ltd.			CHINA
Tungsten			Ganzhou Huaxing Tungsten Products Co., Ltd.			CHINA
Tungsten			Ganzhou Jiangwu Ferrotungsten Co., Ltd.			CHINA
Tungsten			Ganzhou Seadragon W & Mo Co., Ltd.			CHINA
Tungsten			Global Tungsten & Powders Corp.			UNITED STATES OF AMERICA
Tungsten			Guangdong Xianglu Tungsten Co., Ltd.			CHINA
Tungsten			H.C. Starck Smelting GmbH & Co. KG			GERMANY
Tungsten			H.C. Starck Tungsten GmbH			GERMANY
Tungsten			Hunan Chenzhou Mining Co., Ltd.			CHINA
Tungsten			Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji			CHINA
Tungsten			Hunan Chunchang Nonferrous Metals Co., Ltd.			CHINA
Tungsten			Hunan Litian Tungsten Industry Co., Ltd.			CHINA
Tungsten			Hydrometallurg, JSC			RUSSIAN FEDERATION
Tungsten			Japan New Metals Co., Ltd.			JAPAN
Tungsten			Jiangwu H.C. Starck Tungsten Products Co., Ltd.			CHINA
Tungsten			Jiangxi Gan Bei Tungsten Co., Ltd.			CHINA
Tungsten			Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.			CHINA
Tungsten			Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.			CHINA
Tungsten			Jiangxi Xianglu Tungsten Co., Ltd.			CHINA
Tungsten			Jiangxi Xinsheng Tungsten Industry Co., Ltd.			CHINA
Tungsten			Jiangxi Yaosheng Tungsten Co., Ltd.			CHINA
Tungsten			JSC "Kirovgrad Hard Alloys Plant"			RUSSIAN FEDERATION
Tungsten			Kennametal Fallon			UNITED STATES OF AMERICA
Tungsten			Kennametal Huntsville			UNITED STATES OF AMERICA
Tungsten			KGETS Co., Ltd.			KOREA, REPUBLIC OF

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Tungsten			Lianyou Metals Co., Ltd.			TAIWAN, PROVINCE OF CHINA
Tungsten			Malipo Haiyu Tungsten Co., Ltd.			CHINA
Tungsten			Masan Tungsten Chemical LLC (MTC)			VIET NAM
Tungsten			Moliren Ltd.			RUSSIAN FEDERATION
Tungsten			Niagara Refining LLC			UNITED STATES OF AMERICA
Tungsten			Philippine Chuangxin Industrial Co., Inc.			PHILIPPINES
Tungsten			Tejing (Vietnam) Tungsten Co., Ltd.			VIET NAM
Tungsten			Unecha Refractory metals plant			RUSSIAN FEDERATION
Tungsten			Wolfram Bergbau und Hutten AG			AUSTRIA
Tungsten			Woltech Korea Co., Ltd.			KOREA, REPUBLIC OF
Tungsten			Xiamen Tungsten (H.C.) Co., Ltd.			CHINA
Tungsten			Xiamen Tungsten Co., Ltd.			CHINA
Tungsten			Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.			CHINA
Tungsten			Xinhai Rendan Shaoguan Tungsten Co., Ltd.			CHINA

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Appendix B

Sealed Air Corporation

Conflict Minerals Report

For the Year Ended December 31, 2019

Afghanistan, Albania, Angola, Argentina, Armenia, Australia, Austria, Belarus, Belgium, Bermuda, Bolivia, Brazil, Bulgaria, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Czech Republic, Djibouti, Dominican Republic, DRC, Ecuador, Egypt, Eritrea, England, Estonia, Ethiopia, Finland, France, Germany, Ghana, Guinea, Guyana, Hungary, India, Indonesia, Ireland, Israel, Italy, Ivory Coast, Japan, Kazakhstan, Kenya, Kyrgyzstan, Laos, Liberia, Lithuania, Luxembourg, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Nicaragua, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Poland, Portugal, Republic of Korea, Russian Federation, Rwanda, Saudi Arabia, Sierra Leone, Singapore, Slovakia, Slovenia, South Africa, Spain, Sudan, Suriname, Sweden, Switzerland, Tanzania, Thailand, Turkey, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Vietnam, Zambia, Zimbabwe