UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, DC 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
GlaxoSmithKline plc
(Exact name of Registrant as specified in its charter)
| England and Wales | 001-15170 | 98-0607772 |
| (State or other jurisdiction of incorporation) |
(Commission File Number) | (I.R.S. Employer Identification No.) |
GlaxoSmithKline plc
980 Great West Road
Brentford, TW8 9GS
England
(Address of principal executive offices)
Victoria Whyte
Company Secretary
+44 20 8047 5000
(Name and telephone number of this 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-l under the Securities Exchange Act (17 CFR240.13p-l) for the reporting period from January 1 to December 31, 2014.
Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Rule 13p-1 under the Securities Exchange Act of 1934, as amended, (the “Rule”) generally provides that a company must file this specialized disclosure report if it manufactures or contracts to manufacture products for which one or more of the following minerals are necessary to the functionality or production of the company’s products: cassiterite; columbite-tantalite (coltan); and wolframite; their derivatives tantalum, tin, and tungsten; and gold (collectively, “3TGs”). These are considered “conflict minerals” under Rule 13p-1 regardless of their geographic origin and whether or not they fund armed conflict in the Democratic Republic of the Congo or its neighboring countries (the “covered countries”).
GlaxoSmithKline plc (together with its consolidated subsidiaries, “GSK”) is a science-led global healthcare company that researches and develops a broad range of innovative products in three primary areas: Pharmaceuticals, Vaccines and Consumer Healthcare. Our manufacturing network currently includes 84 sites in 36 countries.
Pursuant to the Rule, as described below, we conducted in good faith a technical review of GSK’s products to determine whether 3TGs were present in our products, and for those products that did contain 3TGs, we conducted in good faith a reasonable country of origin inquiry (“RCOI”) that GSK believes was reasonably designed to determine whether any 3TG necessary to the functionality or productions of our 2014 covered products originated in the covered countries or was not from recycled or scrap sources.
GSK obtains (i) materials from suppliers and (ii) finished products from contract manufacturing organizations (“CMOs”) for sales and distribution by GSK.
GSK’s technical review of materials provided by our suppliers indicated that three suppliers provided us with materials containing 3TGs. Using the Electronic Industry Citizenship Coalition and Global e-Sustainability (“EICC-GeSI”) Conflict Minerals Reporting Template, we requested information from these three suppliers regarding their use of 3TG in the materials they provided to GSK. For the calendar year 2014, none of these suppliers indicated to us that any 3TGs contained in materials they provided to GSK came from the covered countries or were not from recycled or scrap sources.
In 2014, GSK conducted a technical review of products supplied by our CMOs for which GSK “contracted to manufacture the products,” as that term is used in the Rule. This review indicated that two of these CMOs provide us with products that we contracted to manufacture that contained 3TGs that were necessary to the functionality or production of a total of two products. Using the EICC-GeSI Conflict Minerals Reporting Template, we requested information from these two CMOs regarding their use of 3TG in the products they provided to GSK. For the calendar year 2014, none of these suppliers indicated to us that any 3TGs contained in products they provided to GSK came from the covered countries or were not from recycled or scrap sources.
GSK has now completed a full review of its 2014 product portfolio. None of our suppliers or CMOs for which we contracted to manufacture products indicated to us that any 3TGs necessary to the functionality or production of the company’s products that were contained in materials or products that they provided to GSK came from the covered countries or were not from recycled or scrap sources. As a result, we have no reason to believe that that any of the 3TGs contained in our 2014 covered products originated in the covered countries or did not come from recycled or scrap sources.
The information in this Form SD also is publicly available on our website at http://www.gsk.com/en-gb/about-us/policies-codes-and-standards/#other-reports.
Item 1.02 Exhibit
Not applicable.
Section 2 – Exhibits
Item 2.01 Exhibits
Not applicable.
SIGNATURE
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 duly authorized undersigned.
| /s/ Simon Dingemans | ||||
| Dated: 29 May, 2015 | Name: Simon Dingemans | |||
| Title: Chief Financial Officer, GlaxoSmithKline plc |