Form sd ardagh group s.a. data recovery tools iphone

Ardagh Group S.A. (together with its consolidated subsidiaries, the “Company,” “Ardagh,” “we,” “our,” or “us”) has prepared this conflict minerals report (“Report”) to comply with Rule13p-1 under the US Securities and Exchange Act of 1934 (the “Rule”). The Rule imposes reporting obligations on Securities and Exchange Commission (“SEC”) registered companies whose manufactured products contain conflict minerals that are necessary to their functionality or production. Conflict minerals are defined as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten (collectively, “Conflict Minerals”). These reporting obligations apply without regard to the geographic origin of the Conflict Minerals and whether or not they fund armed conflict.


This Report covers the reporting year ended December 31, 2017. We note that as a newly listed company Ardagh is entitled to a transition period that would allow us to make our first Report for the reporting year ending December 31, 2018. However, Ardagh has elected to voluntarily comply with the Rule and to submit this Report for the 2017 reporting year.

Ardagh does not use Conflict Minerals in the manufacturing process for our glass packaging products. We do apply a coating to our glass packaging products (monobutyltin-trichloride) that contains tin. However, based on public statements of the SEC staff and SEC staff communications with industry association representatives, we have concluded that organic tin compounds sourced from third parties for use in our glass manufacturing process are not within the scope of the Rule.

Our metal packaging products are made from tin-free steel, electrolytic chromium coated steel or tinplate. The tinplate we use and tinplate components we purchase from suppliers are within the scope of the Rule and are included in our due diligence program relating to Conflict Minerals.

In accordance with the Rule, we conducted, in good faith, a reasonable country of origin inquiry (“RCOI”) designed to determine whether any of the necessary Conflict Minerals in our products originated in the Democratic Republic of the Congo or an adjoining country (“Covered Countries”) or were from recycled or scrap sources.

We used the Responsible Minerals Initiative’s (“RMI”) conflict minerals reporting template (“CMRT”) to obtain sourcing information from our direct suppliers of tinplate or tinplate components. Our RCOI included assessing the responses we received from our suppliers and evaluating smelters in accordance with our due diligence framework described below.

Our due diligence program has been designed to conform in all material respects to 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, and the related Supplement for tin, tantalum and tungsten. Ardagh has implemented the following steps in accordance with our due diligence program:

Ardagh has specifically addressed Conflict Minerals in our Responsible Procurement Policy. The Policy is a working document for Ardagh and is publicly available on our website for our suppliers here: https://www.ardaghgroup.com/userfiles/files/Ardagh-Responsible-Procurement-Policy.pdf.

Our Corporate Social Responsibility Policy, which is included as Appendix 1 to our Code of Conduct , also addresses conflict minerals. Our Code of Conduct is distributed to all Ardagh employees and is publicly available on our website here: https://www.ardaghgroup.com/userfiles/files/Ardagh_Group_Code_of_Conduct_v2.pdf . Our Code of Conduct, which, together with its accompanying policies, applies to all Ardagh directors, officers and employees and third parties working on our behalf, sets forth the values and beliefs of Ardagh, and includes our shared core values of Trust, Teamwork and Excellence.

In addition, we have adopted a Conflict Minerals Procedure to ensure a consistent approach for conflict minerals reporting is followed throughout our organization. This is of critical importance given the complexity of reporting and the size and international nature of the supplier base.

Ardagh employees are able to raise any concerns either via our usual internal reporting mechanisms or by using Ardagh’s Compliance Hotline. Ardagh’s Compliance Hotline Policy, which is set forth in Appendix 12 to our Code of Conduct , further governs this mechanism.

We then identified suppliers that potentially provide tinplate and/or tinplate components and compiled contact information for all relevant suppliers Tinplate suppliers make up the majority of our tinplate spend , with smaller volumes purchased from component suppliers and tinplate traders.

Responses were tracked and the CMRTs and accompanying information were reviewed. In accordance with our due diligence program, we followed up with suppliers that did not upload their information to the system or did not in our view provide sufficient information. We received a response to most follow-up inquiries, either with the CMRT, relevant statements or SEC reports via e-mail. A few suppliers informed us that they do not in fact supply us with products containing tin or that they were not in a position to provide us with supporting documentation.

As a downstream purchaser of materials and components that may contain Conflict Minerals, we must necessarily rely, in good faith, on our direct suppliers to provide us with information about the source of Conflict Minerals contained in the materials and/or components supplied to us. We do not have direct relationships with Conflict Minerals smelters and refiners and do not perform or direct audits of these entities within our supply chain.

The information on smelters provided by our responding suppliers was matched against the RMI’s RMAP Conformant Smelters & Refiners List (“RMI List”). Nearly 73% of the smelters included by our suppliers are certified under the RMI scheme and hence considered conflict-free.

Following such research and follow-up with suppliers, smelters used by two of our responding suppliers could not be verified as conflict-free. Relevant measures to mitigate this risk, as well as improve the response rate to our initial survey request and additional follow-ups, are explained in sections 3.3 and 4 below .

As described above, we collected information from suppliers from their CMRTs and reviewed such responses to identify risks. Potential risks identified, such as incomplete CMRTs or nonresponses, were communicated internally to attempt to address the issue.

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