Blueprint
UNITED STATES SECURITIES AND EXCHANGE
COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
Commission file number 1-10691
DIAGEO plc
(Exact
name of registrant as specified in its charter)
England and Wales
(State or other jurisdiction of incorporate or
organization)
Lakeside Drive, Park Royal, London NW10 7HQ, England
(Address of principal State or other jurisdiction of incorporate or
organization)
James Edmunds, Deputy Company Secretary
Tel: +44 20 8978 6000
E-mail: the.cosec@diageo.com
Lakeside Drive, Park Royal, London NW10 7HQ, England
(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, 2017
Section 1 – Conflict Minerals Disclosure
Diageo plc evaluated its current product lines to confirm whether
tin, tungsten, tantalum and/or gold (“3TG”) are
contained in and necessary to the functionality or production of
certain products manufactured or contracted to be manufactured by
Diageo plc, and determined that tin and gold are currently
applicable (the “Covered Products”). Following a good
faith reasonable country of origin inquiry as required by Item
1.01(a) of Form SD (the “RCOI”) regarding the 3TG in
the Covered Products, Diageo plc has no reason to believe that the
3TG in the Covered Products may have originated in the Democratic
Republic of Congo or an adjoining country (as defined in paragraph
(d)(1) of Item 1.01 of Form SD) (the “Covered
Countries”). As a result Diageo plc has disclosed below,
under a separate heading entitled “Conflicts Minerals
Disclosure,” the determination and described the RCOI that
Diageo plc undertook in making such determination.
Conflict Minerals Disclosure
Determination
Following a good faith RCOI regarding the 3TG in the Covered
Products, Diageo plc has determined that it has no reason to
believe that the 3TG in the Covered Products may have originated in
the Covered Countries.
Description and results of the RCOI
Diageo plc continued with the governance program in place in
relation to conflict minerals (defined as columbite-tantalite
(coltan), cassiterite, gold, wolframite, or certain of their
derivatives (which are currently limited to tantalum, tin, and
tungsten)) (“Conflict Minerals”), including the
steering committee with representation from the procurement and
legal functions of Diageo plc. At the direction of and under the
supervision of the conflicts minerals steering committee, Diageo
plc’s RCOI and due diligence processes were conducted in
three phases, as outlined below.
Phase One: An internal
assessment process was implemented with input from across the
supply, procurement and legal teams to identify all products
manufactured or contracted to be manufactured by Diageo plc that
may potentially contain Conflict Minerals. It was determined that
3TG was potentially necessary to the functionality or production of
certain products manufactured by Diageo plc or contracted to be
manufactured by Diageo plc.
Phase Two: For all products
identified in phase one for which 3TG were potentially necessary to
the functionality or production, Diageo plc conducted a RCOI by
writing to the suppliers of the identified products, requesting
that they complete and return the Conflict-Free Sourcing Initiative
‘Conflict Minerals Reporting Template’ or otherwise
certify in writing the contents and provenance of the supplied 3TG.
Diageo plc received a 100% response rate in relation to products
within scope. This phase enabled Diageo plc to obtain reasonably
reliable evidence and representations in relation to the use of 3TG
in calendar year 2017. Through this process, Diageo plc determined
that: (1) gold flakes were used for Smirnoff Gold and Goldschlager;
and (2) tin was used in brass tubesheets and flanges for distilling
equipment (sold to customers).
Phase Three: Diageo plc
conducted further inquiries by contacting suppliers identified in
phase two as using 3TG in their products, requesting they conduct
an investigation into their supply chain and provide written
representations confirming whether the 3TG may have originated in
the Covered Countries with a 100% response rate in relation to
further inquiries. Diageo plc received reliable evidence and
representations in relation to the provenance of such materials.
These representations indicate that none of the conflict minerals
originate in the Covered Countries. In the process of obtaining
such representations and its due diligence process more generally,
Diageo plc encountered no warning signs or circumstances suggesting
otherwise.
Based on the good faith RCOI described above, Diageo plc has
concluded that it has no reason to believe that the Conflict
Minerals used in products manufactured or contracted to be
manufactured by Diageo plc and necessary to their functionality or
production may have originated in the Covered
Countries.
A copy of Diageo plc’s Conflict Minerals Disclosure is
publicly available at www.diageo.com following the pathway to
/in-society/building-thriving-communities/sustainable-supply-chains/.
Signature
Diageo
plc
(registrant)
/s/ KA Mikells
_________________________
Name: Kathryn Mikells
Title:
Chief Financial Officer