Conflict Minerals Policy

In recent years, global awareness of the significant adverse impacts resulting from mineral mining and extraction operations in certain conflict-affected and high-risk areas of the world has increased. Tin, tantalum, tungsten, their ores and mineral derivatives, and gold (“conflict minerals”) emanating from the Democratic Republic of Congo (DRC) and adjoining countries have been identified as products of such mining operations that can make their way into the global manufacturing supply chain. Armed groups engaged in mining operations in the DRC have been linked to human rights abuses and violations of national or international law, and are believed to be using the proceeds of the mining operations to fund conflict in the country. As required by the Dodd-Frank Wall Street Reform and Consumer Protection Act, the United States Securities and Exchange Commission (SEC) has issued regulations that require U.S. companies, including Greif, Inc., to report on the use of conflict minerals in their products.

Greif is directed by the core principles of our business, called the Greif Way, and is committed to ethical business practices and compliance with all applicable laws and regulations. We are therefore dedicated to working with our customers and suppliers to source in a responsible manner the materials we use in manufacturing our products. To comply with the SEC reporting regulations relating to conflict minerals, we have reviewed and will continue to review our use of these minerals in our products and our global supply chain management system in accordance in all material respects with the general principles set forth in the OECD’s Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “Guidance”).

Consistent with the Guidance, we will work to:

  • Maintain a strong supply chain management system;
  • Identify and assess risks within our supply chain; and
  • Design and implement strategies to respond to identified risks.

As part of our supply chain management system, we will require that our suppliers:

  • Assist us in complying with the SEC regulations related to conflict minerals by providing reasonably requested information from time to time;
  • Establish conflict minerals policies that affirm our commitment to ethical business practices and that are consistent with the Guidance;
  • Undertake all reasonable due diligence within their supply chains to determine the origin of conflict minerals and meet all applicable SEC reporting requirements; and
  • Cooperate with Greif and/or its representatives in connection with any on-site inspections or audits of suppliers’ due diligence procedures and systems related to conflict minerals.

The process of tracing conflict minerals through any supply chain is complicated and time-consuming. However, Greif is committed to working with our customers and our suppliers to ensure effective implementation of this legislation and its related regulations.