Download FORM SD Specialized Disclosure Report Multi - corporate

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
FORM SD
Specialized Disclosure Report
Multi-Color Corporation
(Exact name of registrant as specified in charter)
Ohio
(State or other jurisdiction
of incorporation)
4053 Clough Woods Drive
Batavia, OH
(Address of principal executive offices)
0-16148
(Commission
File Number)
31-1125853
(IRS Employer
Identification No.)
45103
(Zip Code)
Sharon E. Birkett
(513) 381-1480
(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:
_X_
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31,
2015.
Section 1. Conflict Minerals Disclosure.
Item 1.01. Conflict Minerals Disclosure and Report.
Multi-Color Corporation ("Multi-Color" or the "Company") evaluated its products during the year ended December 31, 2015 and
determined that certain products manufactured or contracted to be manufactured by the Company contain tin, tungsten, tantalum,
and/or gold. As a result, the Company has filed a Conflict Minerals Report ("CMR"). A copy of the Company's CMR is available on
the Company's website at www.mcclabel.com.
Item 1.02. Exhibits.
A copy of the Company's CMR is furnished as Exhibit 1.01 to this Form SD and is incorporated herein by reference.
Section 2. Exhibits.
Item 2.01 Exhibits.
(d) Exhibits
No.Description
1.01 Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form SD
SIGNATURES
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 hereunto duly authorized.
MULTI-COLOR CORPORATION.
Dated: May 31, 2016
By: /s/ Sharon E. Birkett
Sharon E. Birkett
Vice President, Chief Financial Officer, Secretary
EXHIBIT 1.01
Multi-Color Corporation
Conflict Minerals Report
For The Year Ended December 31, 2015
This report for the year ended December 31, 2015 (the "Reporting Period") is presented to comply with Rule 13p-1 under the
Securities Exchange Act of 1934 (the "Rule") and the Public Statement on the Effect of the Recent Court of Appeals Decision on the
Conflict Minerals Rule issued by the Director of the Division of Corporation Finance of the Securities and Exchange Commission on
April 29, 2014 (the "SEC Statement"). The Rule was adopted by the Securities and Exchange Commission ("SEC") to implement
reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer
Protection Act of 2010 ("Dodd-Frank Act"). The Rule imposes certain reporting obligations on SEC registrants whose manufactured
products contain conflict minerals which are necessary to the functionality or production of their products. Conflict minerals are
defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold
(collectively, "3TG") for the purposes of this assessment. These requirements apply to all registrants whatever the geographic origin of
the conflict minerals and whether or not they fund armed conflict.
If a registrant can establish that the conflict minerals originated from sources other than the Democratic Republic of the Congo
("DRC") or an adjoining country (collectively, the "Covered Countries"), or from recycled and scrap sources, they must submit a
Form SD which describes the Reasonable Country of Origin Inquiry ("RCOI") completed.
If a registrant has reason to believe that any of the conflict minerals in its supply chain may have originated in the Covered Countries,
or if it is unable to determine the country of origin of those conflict minerals, then the issuer must exercise due diligence on the
conflict minerals' source and chain of custody. The registrant must annually submit a Conflict Minerals Report ("CMR") to the SEC
that includes a description of those due diligence measures.
1.
Company Overview
Multi-Color Corporation ("Multi-Color" or the "Company"), which was incorporated in 1985 and is headquartered in Cincinnati,
Ohio, is a leader in global label solutions supporting a number of the world's most prominent brands including leading producers of
home & personal care, wine & spirit, food & beverage, healthcare and specialty consumer products. Multi-Color serves international
brand owners in North, Central and South America, Europe, Australia, New Zealand, South Africa, China and Southeast Asia. With a
comprehensive range of the latest label technologies in Pressure Sensitive, Glue-Applied (Cut and Stack), In-Mold, Shrink Sleeve and
Heat Transfer.
2.
Products and Facilities Overview
The Company manufactures a comprehensive range of the latest label technologies in Pressure Sensitive, Glue-Applied (Cut and
Stack), In-Mold, Shrink Sleeve and Heat Transfer. An analysis of Multi-Color products found that 3TG can be found in a small
amount of Multi-Color's labels. Therefore, the products that Multi-Color manufactures or contracts to manufacture are subject to the
reporting obligations of Rule 13p-1.
As of December 31, 2015, the Company owned and leased 45 manufacturing facilities in U.S., Argentina, Australia, Canada, Chile,
China, England, France, Indonesia, Ireland, Italy, Malaysia, Mexico, the Philippines, Poland, Scotland, South Africa, Spain,
Switzerland, and Thailand.
Multi-Color does not have direct business relationships with any smelters or refiners that process 3TG, and the Company does not
directly source any products from the Covered Countries. In light of the Company's remote position in the supply chain, the Company
must rely upon its suppliers, and their multiple lower tier suppliers, to comply with Multi-Color's conflict mineral policy, engage in
due diligence of their respective supply chains and to provide information on and verification of the chain of custody of conflict
minerals in Multi-Color's products.
3.
Reasonable Country of Origin Inquiry ("RCOI")
Multi-Color's due diligence program includes a reasonable country of origin inquiry ("RCOI"). An RCOI is an inquiry regarding the
origin of conflict minerals that is designed to determine where the minerals used by Multi-Color's suppliers originated or if they are
from recycled or scrap sources. After conducting a good faith RCOI, the Company is unable to determine the origin of all of the 3TG
used in its products, although the Company is able to determine that some of the 3TG used in its products does not originate in a
Covered Country.
4.
Due Diligence Process and Findings
In response to the Rule, Multi-Color designed due diligence measures relating to the Rule and conflict minerals. The Company has
looked to industry guidelines to help establish its programs such as the Conflict Minerals Reporting Template developed by the
Conflict-Free Sourcing Initiative ("CFSI") that facilitates the transfer of information through the supply chain regarding mineral
country of origin and smelters and refiners being utilized. The Company intends to further develop transparency into its supply chain
by further leveraging the industry standard CFSI program and continuing outreach efforts to suppliers, but it will take time for some of
Multi-Color's suppliers to verify the origin of all of the minerals due to the breadth and complexity of the supply chain.
The Company's due diligence efforts have been developed in conjunction with the 2nd edition of The Organization 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 supplements for gold and for tin, tantalum, and tungsten. The Company
introduced and continues to develop a supply chain transparency process to attempt to identify the sources of the 3TG used in its
products and to gather information about supplier conflict-free policies.
For the Reporting Period, the Company conducted a survey of all suppliers where the nature of the component indicated that those
components were likely to contain 3TG. As noted above, the Company does not have direct relationships with the smelters and
refiners of minerals or metals used in the Company's products, and the Company's due diligence processes are subject to inherent
limitations given the complexity of the Company's supply chain and the inherent limitations based on the necessity to seek information
from direct suppliers, and those suppliers seeking information from their lower tiered suppliers. After exercising the due diligence
process described above, the Company was not able to determine the sources of all conflict minerals necessary to the Company's
products' functionality or product, or whether or not any such conflict minerals may have, in fact, directly or indirectly financed or
benefitted armed groups in the Covered Countries; provided, however, that the due diligence process was able to confirm that certain
of the Company's suppliers manufactured or contracted to manufacture products that contain conflict minerals but do not originate
from a Covered Country.
The Company will continue to implement commercially reasonable processes to improve the quantity and quality of supplier
responses and to verify supplier responses.