SD 1 d122363dsd.htm FORM SD Form SD



Washington, D.C. 20549


Specialized Disclosure Report

Anheuser-Busch InBev SA/NV


(Exact name of registrant as specified in its charter)


Belgium   1-37911   None
(State or other jurisdiction
of incorporation or organization)
File Number)
  (IRS Employer
Identification No.)


Brouwerijplein 1       3000 Leuven, Belgium
(Address of principal executive offices)     (Zip Code)


Jan Vandermeersch

Global Legal Director

Anheuser-Busch InBev SA/NV

+32 16 27 61 11



(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, 2020.

Section 1 – Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

Conflict Minerals Disclosure

Anheuser-Busch InBev SA/NV (together with its consolidated subsidiaries, “AB InBev”, “Company”, “we” or “our”) hereby files this Form SD pursuant to Rule 13p-1 under the Securities Exchange Act of 1934. Please refer to Rule 13p-1, Form SD and the 1934 Act Release No. 34-67716 for definitions to the terms used in this Report, unless otherwise defined herein. A copy of this Form SD is also posted to the Company’s website at: .

AB InBev has determined that it manufactures two products employing necessary conflict minerals within the scope of Form SD:



A line of glass bottles manufactured by an AB InBev subsidiary utilizes the coating Certincoat® TC100, which contains the conflict mineral tin necessary for its functionality. AB InBev is supplied Certincoat® TC100 by a single supplier.



One of AB InBev’s subsidiaries manufactures crowns, which include tin-plated steel (“ETP”) that is sold to third parties. AB InBev is supplied ETP by a single supplier.

Reasonable Country of Origin Inquiry

AB InBev first provided a detailed questionnaire to its supplier of Certincoat® TC100 to ascertain its diligence processes in sourcing the conflict mineral tin for fiscal year 2013. The supplier provided AB InBev with a completed Electronic Industry Citizenship Coalition and Global e-Sustainability Initiative (“EICC/GeSI”) Conflict Minerals Reporting Template (“EICC/GeSI Template”), a template developed in accordance with 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. AB InBev’s supplier has updated its EICC/GeSI Template responses for fiscal year 2020. In its completed EICC/GeSI Template, the supplier confirmed that it has received completed EICC/GeSI Templates from 100% of its smelters. The supplier compared its list of smelters with information provided by the Conflict-Free Sourcing Initiative (“CFSI”). The CFSI, through its Conflict-Free Smelter Program, uses independent third-party audits to certify smelters and refiners that have systems in place to assure sourcing of only “conflict free” materials. A list of smelters and refiners that are considered compliant with the Conflict-Free Smelter Program audit protocols, as determined by the CFSI, is published on the CFSI website. According to the supplier, all the parties providing replies confirmed that the tin sourced either was not from the Democratic Republic of the Congo (“DRC”) or an adjoining country, or was on the CFSI’s approved “conflict free” list. The supplier’s replies identified nine smelters from which the supplier obtained tin, and there is no indication that any of these smelters sourced tin from the DRC or an adjoining country. The supplier also provided its internal Conflict Minerals Policy confirming its commitment to responsible sourcing and its commitment to use its best efforts not to acquire conflict minerals from the DRC or an adjoining country unless such materials are certified as “conflict free”.

AB InBev has also provided the EICC/GeSI Template form to its supplier of ETP, which has not yet responded to its inquiries. AB InBev continues to engage with the supplier to receive the completed EICC/GeSI Template form and further details of the supplier’s policies on conflict minerals as well as any other documentation regarding its management systems and due diligence processes on this matter.

Based on the documentation it has received from its supplier, AB InBev has no reason to believe that necessary conflict minerals it purchased from January 1, 2020 to December 31, 2020 triggered any additional filing requirements, and has concluded that its due diligence represents a good faith and reasonable effort to determine the origins of the tin used in its supply chains.

Item 1.02 Exhibit


Section 2 – Exhibits

Item 2.01 Exhibits





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 thereunto duly authorized.





/s/ Jan Vandermeersch

    Date:    May 28, 2021                

Jan Vandermeersch

Global Legal Director Corporate