Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2020.

Exhibit No.

Description

We maintain a policy publicly available on our website at www.averydennison.com/conflictminerals that reflects our goal to refrain from purchasing components containing conflict minerals from the Covered Countries, unless those materials are certified by an independent third party to originate from conflict-free/conformant sources.

Our governance model to oversee the implementation and ongoing management of our conflict minerals compliance program includes a steering committee performing oversight and ensuring regulatory compliance and a core team responsible for product assessment and the RCOI process. The steering committee engages with senior leadership from our business units and corporate functions to develop, document and maintain a governance structure that enables sustainable compliance and satisfies regulatory requirements.

We maintain processes to evaluate parts and suppliers in the supply chain for potential conflict minerals risk. Our global supplier standards and restricted substances lists are updated as needed to ensure that suppliers provide information on their use and sourcing of conflict minerals. We periodically engage with industry associations to help enhance transparency and traceability in the supply chain. We use a standardized documentation format to capture key program decisions, processes, and procedures and we maintain conflict minerals records for ten years under our document retention policy.

We have advised suppliers of our conflict minerals policy, have updated our supplier requirements to expressly incorporate the policy, and provided at-risk suppliers with additional information to facilitate their understanding and ensure our compliance with Section 1502 and Rule 13p-1.

We maintain a telephone and web-based whistleblower hotline available at all hours for employees or third parties to report compliance concerns to our company, anonymously if they so choose. This hotline is operated by an independent third party and accepts reports in any language to accommodate the needs of our global workforce and customer/supplier base. Parties may use this existing system to provide information or voice their concerns regarding our sourcing and use of conflict minerals. The hotline may be reached by (i) calling 800.461.9330 toll-free in the United States, 720.514.4400 direct with applicable charges from any location, or toll-free outside of the United States using the country-specific toll-free numbers found in our Code of Conduct (accessible at averydennisonvaluesandethics.com) or (ii) visiting averydennison.com/guidelinereport (averydennison.com/guidelinereport-eu in Europe).

We analyzed components of products for necessary conflict minerals and assessed the risks they contain conflict minerals from the Covered Countries.

We required identified suppliers to complete a survey based on the Responsible Minerals Initiative (“RMI”) Conflict Minerals Reporting Template (“CMRT”).

We reviewed the responses received and followed up with suppliers that did not return a completed survey. We reviewed survey responses and validated them for completeness and sufficiency. Based on this review, each survey was assigned a conflict minerals status of Conformant, Active, Known or Unknown. Specific supplier corrective actions depend on factors such as supplier size, risk level and supplier capabilities.

Our core conflict minerals team reviewed aggregate supplier survey responses and key reporting metrics.

We conducted a review of summary smelter information received to determine if the smelter has been certified as Conformant, indicating the highest degree of certified compliance with RMI protocols and global sourcing standards, or presents a “red flag” as defined by the OECD Guidance. To make the determination of each smelter’s conflict status, we relied upon information provided by RMI. RMI conducts a Responsible Minerals Assurance Process under which it certifies smelters and refiners worldwide after confirming specific information, including country of origin, for conflict minerals that the smelter/refiner may purchase for its operations. RMI makes available to the public the list of smelters/refiners that it has certified as Conformant.

We conduct a gap analysis on an annual basis after completing our due diligence procedures and we review identified risks and gaps — as well as recommended action plans to mitigate risks and close gaps — with the steering committee.

With oversight from our Board of Directors, management is responsible for managing the day-to-day risks confronting our businesses, including enterprise risk management. In addition, we have robust global processes that support a strong internal control environment to promote the early identification and continued management of risks by our company’s leadership. In this context, we routinely refine our risk mitigation strategy with the goal of systematically reducing the extent of exposure to significant identified risks and minimizing the likelihood of their occurrence. We continue to refine our risk management plan for risks associated with conflict minerals consistent with these existing processes.

We continue to implement our conflict minerals risk management plan as we continue our due diligence procedures and obtain additional information regarding our conflict minerals risk exposure.

Additional fact finding, risk assessments, and changes in circumstances are assessed during our annual review of our conflict minerals compliance program.

In accordance with the OECD Guidance, we continue to build relationships with industry organizations regarding third party audits of smelter/refiner due diligence practices.

We have implemented a process annually to summarize, review, and approve conflict minerals compliance results, complete the Form Specialized Disclosure (Form SD) and Conflict Minerals Report required by Rule 13p-1, and timely file them with the Securities and Exchange Commission.

Based on our current assessment, an aggregate of approximately 2,000 components used in our Retail Branding and Information Solutions and Industrial and Healthcare Materials reportable segments contain conflict minerals. These components are used in products that represented approximately 8% of our consolidated revenues for fiscal year 2020. No components used in our Label and Graphic Materials reportable segment, which represented 67% of our net sales in fiscal year 2020, were found to contain conflict minerals.

Suppliers providing components containing necessary conflict minerals to our impacted business units were included in the RCOI process. Completed responses were received from 82% of the 78 surveyed suppliers, an increase from the 72% response rate for the 100 surveyed suppliers in 2019.

Based on the supplier representations contained in the survey responses received through May 7, 2021, a subset of components provided to us has been determined to contain conflict minerals originating from the Covered Countries. These components primarily originated from smelters/refiners that have been certified by RMI as Conformant. However, suppliers responding to our inquiries indicated that the information provided in their responses was for their customers as a whole, rather than us in particular; as a result, we have been unable to fully determine whether our necessary conflict minerals were sourced from the Covered Countries or came from recycled or scrap sources.

We have been unable to fully determine and describe the facilities used to process our necessary conflict minerals.

Consistent with the OECD Guidance for downstream companies such as us, our efforts to determine the mine or location of origin of our necessary conflict minerals encompassed the due diligence procedures described above and have not been conclusive.

Our supplier responses included Conformant, Active, Known, and Unknown smelters. The status of the reported smelters was 70% Conformant, 7% Active, 22% Known and 1% Unknown. To provide transparency into our supply chain and based on the information provided by the responding suppliers for 2020, we believe that the facilities that may have been used to process the 3TGs in our products include the Conformant, Active and Known smelters and refiners listed in the Appendix attached hereto.

Metal

Smelter

Identification

Smelter Reference List

Smelter Location

RMI

Verified

Metal

Smelter

Identification

Smelter Reference List

Smelter Location

RMI

Verified

Metal

Smelter

Identification

Smelter Reference List

Smelter Location

RMI

Verified

Metal

Smelter

Identification

Smelter Reference List

Smelter Location

RMI

Verified

Metal

Smelter

Identification

Smelter Reference List

Smelter Location

RMI

Verified

Metal

Smelter

Identification

Smelter Reference List

Smelter Location

RMI

Verified