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, 2020
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 conflict minerals
working group with representation from the procurement and legal
functions of Diageo plc. At the direction of and under the
supervision of the conflicts minerals working group, Diageo
plc’s RCOI and due diligence processes were conducted in two
phases, as outlined below.
Phase One: An internal assessment
process was implemented with input from the Diageo 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
confirmation on whether the identified products contained 3TG or
not. Through this process, Diageo plc determined that: (1) gold
flakes were used for Smirnoff Gold; and (2) tin was used in brass
tubesheets and flanges for distilling equipment (sold to
customers). For all products in scope, Diageo requested suppliers
conduct an investigation into their supply chain and provide
written representations confirming whether the 3TG may have
originated in the Covered Countries, receiving a 100% response
rate. As part of this RCOI, Diageo requested the suppliers to
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 reliable
evidence and representations in relation to the use of 3TG in
calendar year 2020. 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 via following the pathway to
/society-2030/pioneer-grain-to-glass-sustainability/responsible-sourcing/.
Signature
DIAGEO plc (REGISTRANT)
1 June
2021
/s/ James
Edmunds
Name:
James Edmunds
Title:
Deputy Company Secretary
Dates Referenced Herein and Documents Incorporated by Reference
