冲突矿产政策

政策声明

皇冠控股有限公司., together with its consolidated subsidiaries (collectively, “公司”), recognizes that it has an opportunity to promote human rights where it can make a positive contribution and an obligation to operate in compliance with all applicable laws wherever it does business. 这项义务包括遵守美国法律.S. 法律¹, which aim to prevent the use of certain minerals if they are sourced in a way that directly or indirectly finances or benefits armed groups in certain “Covered Countries².“受影响的矿物包括铌钽矿, also known as coltan (the metal ore from which tantalum is extracted), cassiterite (the metal ore from which tin is extracted), 黄金, wolframite (the metal ore from which tungsten is extracted), 以及它们的导数, “3TG”). 3TG minerals that are sourced in a way that directly or indirectly finances or benefits armed groups in Covered Countries are referred to as “conflict minerals.”

过程

The Company aims to avoid the use of conflict minerals in the manufacture of its products and is committed to complying with its reporting obligations under applicable law. 相应的, the Company has implemented due diligence measures for tracing and sourcing 3TG in its products designed in conformance with the due diligence related steps of the framework in The Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, 第三版, 以及3TG的相关补充剂, consistent with the Company’s position as a downstream company. The Company also relies on information from the Responsible Minerals Assurance Process (“RMAP”), a voluntary initiative managed by the Responsible Minerals Initiative (the “RMI”), in which an independent third party audits the procurement activities of a smelter or refiner to determine, 有理由相信, that the minerals it processes originated from conflict-free sources.

识别其供应链中的风险, the Company first assesses the likelihood of the presence of conflict minerals in each of its products. The Company has determined that most of its steel containers and container components (e.g.(罐头、罐盖和瓶盖)含有锡.  The Company also has determined that its can-making and transit packaging machinery and equipment products, as well as the tools (and spare parts) that it makes for transit packaging, 可能含有3TG. Because the Company is typically several tiers removed from the smelter or refiner and mineral origin of products in its supply chain, the Company relies principally on its direct suppliers to provide it with sourcing information. 因此，公司联系, 按年计算, all of the first-tier suppliers of tinplate steel for its metal packaging business and almost all of the first-tier suppliers for its can-making machinery business and transit packaging machinery, equipment and tool-making business to request information regarding the source and chain of custody of 3TG minerals in its supply chain. 便于收集完整, 准确的, 标准化和可验证的信息, the Company relies primarily on the Conflict Minerals Reporting Template (the “CMRT”) made available by the RMI. The CMRT facilitates the transfer of information through the supply chain regarding country of origin, 矿山位置和使用的冶炼厂. 

从供应商处收到完整的cmrt后, the Company assesses the due diligence efforts of any identified smelter or refiner by examining the information provided in the CMRT to determine if the smelter or refiner has been validated under the RMI’s RMAP as “Conformant.” The RMAP provides information regarding those smelters or refiners that, 经过独立的第三方审计, have been found to be compliant with the RMAP’s assessment protocols to assure sourcing of only conflict-free materials. 哪里无法获得RMI的信息, 公司进行自己的尽职调查, which includes: contacting its first-tier suppliers for additional information, conducting internet research and analyzing the likelihood that the 3TG originated from a Covered Country based on the smelter’s location.

The Company continues to evaluate its relationships with its suppliers based upon the respective responses of such suppliers and its own due diligence. 在与马口铁供应商签订的所有书面合同中, and in most written contracts with suppliers to its machinery, 设备和工具制造业务, the Company includes an obligation of the supplier to cooperate in its efforts to eliminate conflict minerals from the supply chain. The Company’s 供应商行为准则 includes a provision regarding responsible sourcing (Origin Mapping). Suppliers who do not comply with the Company’s conflict minerals policy and procedures may be denied future business by the Company and those who violate contractual provisions or policies are subject to enforcement actions by the Company.

¹看到,e.g., 1934年证券交易法第13p-1条, 修订的, 以及美国政府的规章制度.S. Securities and Exchange Commission (the “SEC”) with respect thereto, and Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.

²定义见SEC发布号. 34-67716(2012年8月22日)