Washington, DC 20549






Spectrum Brands Holdings, Inc.

(Exact name of registrant as specified in its charter)


Delaware 001-4219

(State or other jurisdiction of



File Number)


SB/RH Holdings, LLC

(Exact name of registrant as specified in its charter)


Delaware 333-192634-03

(State or other jurisdiction of



File Number)



3001 Deming Way

Middleton, Wisconsin 53562

(608) 275-3340

(Address of principal executive offices)


Ehsan Zargar

Executive Vice President

General Counsel and Corporate Secretary

(608) 275-4924

(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, 2023.


Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended ___.







Section 1 - Conflict Minerals Disclosure


Item 1.01 Conflict Minerals Disclosure and Report


As contemplated by Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD, a Conflict Minerals Report for the reporting period from January 1 to December 31, 2023 is provided as an Exhibit to this Form SD and is available on our website at https://spectrumbrands.com/about-us/our-company/corporate-compliance-and-social-responsibility.html


Our website is not incorporated by reference and should not be considered part of this Form SD or our Conflict Minerals Report.


Item 1.02. Exhibit


The Conflict Minerals Report described in Item 1.01 is filed as Exhibit 1.01 to this Form SD.


Section 2 – Resource Extraction Issuer Disclosure


Item 2.01 Resource Extraction Issuer Disclosure and Report.


Not applicable


Section 3 - Exhibits


Item 3.01. Exhibits


The following exhibit is filed as part of this report:


Exhibit No.   Exhibit
1.01   Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.








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.





Date: May 31, 2024 By: /s/ Ehsan Zargar  
    Name: Ehsan Zargar  

Executive Vice President, General Counsel, and Corporate Secretary









Conflict Minerals Report

This is the Conflict Minerals Report of Spectrum Brands Holdings, Inc. and its consolidated subsidiaries, including SB/RH Holdings, LLC and its consolidated subsidiaries (the “Company,” “Spectrum,” “we,” “us,” or “our”), for January 1, 2023 through December 31, 2023 (“Calendar Year 2023”) in accordance with Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934, as amended (the “1934 Act”). Please refer to Rule 13p-1, Form SD and the 1934 Act Release No. 34-67716 for definitions of the terms used in this Report, unless otherwise defined herein.

Applying the Dodd-Frank Act to Spectrum Brands Holdings, Inc.

The Securities and Exchange Commission’s (the “SEC”) conflict minerals rules require a three-step compliance approach. The first step is determining applicability of the conflict minerals rules to Spectrum; the second step is a reasonable country of origin inquiry (“RCOI”) to determine whether we have reason to believe that conflict minerals from the Democratic Republic of Congo (the “DRC”) or adjoining countries (the “Covered Countries”) that are necessary to the functionality or production of products manufactured by us, or contracted to be manufactured by us, are present in our products; and the third step (referred to as “due diligence” in the SEC rules) is to determine the source and origin of any such conflict minerals and the facilities in which they were processed.

As a downstream company, Spectrum is several tiers removed from mining operations and smelters or refiners (“SORs”) in dealing with its direct suppliers. Spectrum hired a third-party provider to assist it in performing conflict mineral supply chain due diligence (the “Provider”). Using our Provider as well as our supply chain due diligence processes and focusing on accountability within the supply chain by using the industry standard Responsible Minerals Initiative’s (“RMI”) Conflict Minerals Reporting Template (“CMRT”) and reaching out to our suppliers, we hope to gain greater transparency in our supply chain.

Due Diligence Framework and Resources

Spectrum undertook due diligence to determine if conflict minerals were necessary to the production or functionality of its products. In conducting its due diligence, Spectrum implemented the Organization for Economic Co-Operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Framework”), an internationally recognized due diligence framework, and related supplements for each of the conflict minerals. Accordingly, the steps taken by Spectrum in preparing this Conflict Minerals Report were in accordance with the OECD Framework. As such, we used the RMI’s CMRT, which includes standard supply chain survey and information tracking methods to: (i) determine if our manufactured products contained conflict minerals necessary to their functionality or production, (ii) perform a RCOI to determine whether such minerals originated in the DRC or a Covered Country, or are from recycled or scrap sources, and (iii) assess our supply chain’s adherence to due diligence measures stated by the OECD Framework.

Reasonable Country of Origin Inquiry

Our Steering Committee reviewed the products manufactured or contracted to be manufactured by the Company in order to determine which products might contain conflict minerals that are necessary to their functionality or production; the list of products is contained on Attachment A to this Conflict Minerals Report. The Company conducted this review at a product level. A list of the suppliers determined to be in-scope for purposes of the conflict minerals rules was compiled and the RCOI was conducted as follows:

a.Spectrum sent initial inquiries to 136 suppliers and instructed them to complete the CMRT and return it to Spectrum.
b.During Fiscal Year 2024 (October 1, 2023 through September 30, 2024) (“Fiscal Year 2024”), Spectrum hired the Provider to engage its suppliers to collect information about the presence and sourcing of conflict minerals used in the products and components supplied to Spectrum in the


Calendar Year 2023 and by doing so add more transparency to Spectrum’s supply chain with the ultimate goal of identifying the related smelters or refiners and associated mine countries of origin.

c.Spectrum and the Provider conducted up to eight follow-up inquiries of the initially unresponsive suppliers.
d.Spectrum and the Provider also conducted follow-ups with suppliers for further information if initial responses were incomplete or unclear.
e.Spectrum performed follow-ups (up to two times) with suppliers who returned an incomplete CMRT; all issues were addressed.
f.The Provider also evaluated the completed CMRTs for plausibility, consistency and gaps. Additional supplier contacts were conducted to attempt to resolve “quality control” flags, such as: (a) Smelters or Refiners (SORs) were not provided for a used metal, (b) Supplier listed one or more SORs for an unused metal, (c) supplier indicated that it had not identified all SORs for the in-scope products, (d) supplier indicated it had not received conflict minerals data for each metal from all of its relevant suppliers, or (e) supplier indicated that all of its conflict minerals were from recycled or scrap sources, but one or more of the SORs listed are not known to be exclusive recyclers.
g.After follow-up, Spectrum had a 90% supplier response rate, with 29.41% of the responding suppliers indicating that one or more of the conflict minerals are necessary to the functionality or production of the products they supply to Spectrum.

Due Diligence Steps Performed

1.Steps Taken to Establish Strong Company Management Systems
a.Spectrum continued disseminating conflict minerals information and updates through its Steering Committee, which implements and manages Spectrum’s conflict minerals compliance program.
b.Spectrum is committed to sourcing components and materials from companies that share its values about human rights, ethics and environmental responsibility. Spectrum’s employees and the Steering Committee continue to enforce its Conflict Minerals Policy, which is available on the Company’s website at https://spectrumbrands.com/about-us/our-company/corporate-compliance/conflict-minerals.html. As required by our Conflict Minerals Policy, all of our suppliers are required to sign Spectrum’s Supplier Code of Conduct, which includes requirements relating to conflict minerals and responsible sourcing. A copy of Spectrum’s Supplier Code of Conduct can be found at https://www.spectrumbrands.com/about-us/suppliers/supplier-code-of-conduct.html. Spectrum’s Supplier Code of Conduct (the “Code”) incorporates requirements related to conflict minerals so that current and future suppliers are obligated to comply with Spectrum’s policies on conflict minerals, including participation in related due diligence activities.
c.Spectrum educates its employees and, in addition the Steering Committee, disseminates conflict minerals information through division heads, supply chains, and sales forces.
d.Spectrum maintains a grievance mechanism to enable the reporting of grievances related to conflict minerals and other supply chain matters.
e.Spectrum retains conflict minerals program documentation in accordance with the Company’s record retention policies.


2.Steps Taken to Identify Risks in the Supply Chain and Strategies to Respond to Identified Risks.
a.Spectrum identified the products it manufactured or contracted to manufacture in Calendar Year 2023.
b.Spectrum identified 40 suppliers from whom it purchases components used in the production of those products, and which could contain conflict minerals necessary to the functionality or production of such products and solicited information from such suppliers as part of its RCOI. Spectrum, with the assistance of the Provider, compared the list of the SORs collected to the Provider’s SOR database, which incorporates information from the lists publicly published by the RMI. Attached hereto as Exhibit A is a list of SORs identified by our suppliers with valid smelter certification identification numbers.

Spectrum performed, and continues to perform, risk mitigation efforts to bring suppliers into conformity with its Conflict Minerals Policy and contractual requirements. These efforts included working with direct suppliers during Spectrum’s supplier meetings to consider alternative sources of components or supplying components which contain conflict minerals from OECD-conformant sources based on the internationally recognized certifications. Spectrum publicly communicated its Conflict Minerals’ Policy on its website at https://spectrumbrands.com/about-us/our-company/corporate-compliance/conflict-minerals.html.

3.Carry out independent third-party audit of smelter/refiner due diligence practices.

The Company uses information provided by independent third party audit programs, including the (RMI), London Bullion Market Association (LBMA), and Responsible Jewelry Council (RJC), to confirm the existence and verify the OECD conformance status of SORs identified during due diligence. We are many steps removed from the mining of conflict minerals. We do not purchase raw ore or unrefined conflict minerals, and we do not conduct any purchasing activities directly in the Covered Countries.

4.Mitigation Steps Spectrum Has Taken or Will Take Since the End of Calendar Year 2023.

We undertook the following steps since the end of Calendar Year 2023 to mitigate the risk that our products may contain conflict minerals that benefit armed groups within the Covered Countries, including steps to improve our due diligence:

a.Continued to enforce our Conflict Minerals Policy, which is embedded in our Code, and disseminate the Code to those suppliers who provide raw materials and components in Spectrum’s manufacturing operations and Spectrum’s contract manufacturers.
b.Continued to enforce the process within Spectrum’s manufacturing operations/procurement function to notify new vendors of our conflict minerals policy within the Code.
c.Published a copy of our current Form SD and this Conflict Minerals Report on our website at https://spectrumbrands.com/about-us/our-company/corporate-compliance-and-social-responsibility.html.
d.Continued our supply chain due diligence with the assistance of our Provider, on the source and chain of custody of raw materials and components purchased for Spectrum’s manufacturing operations. Spectrum plans to continue to enhance supplier communication and training on conflict minerals. Spectrum values its supplier relationships, but if any supplier is at risk to or violates Spectrum’s Conflict Minerals Policy or its Code, Spectrum plans to require a corrective action plan from the supplier and move towards conflict free sourcing. Spectrum will not ban sourcing from the Covered Countries, but it seeks to procure materials from responsible sources in the region to assist legitimate, conflict-free businesses there.


e.Because of Spectrum’s size, the complexity of its products, and the depth, breadth and constant evolution of its supply chain, it is difficult to identify sub-tier suppliers downstream from its direct suppliers. Spectrum does not purchase products directly from any suppliers, smelters, refiners or mines in the Covered Countries and has no direct contractual relationships with smelters and refiners, as previously noted. Instead, it relies on its direct suppliers to gather and provide specific information about the source of conflict minerals contained in the components supplied to it. Spectrum’s direct suppliers are similarly reliant upon information provided by their suppliers. Therefore, the Provider’s assistance with unresponsive first tier suppliers will be valuable to continue to add transparency to the Spectrum supply chain. Our suppliers identified 134 smelters/refiners potentially in the Spectrum supply chain that our Provider’s database indicated as having valid smelter certification identification numbers. Additional investigation was undertaken to determine the source of and chain of custody of the regulated metals. The following internationally accepted audit standards were checked to determine the OECD conformance status of the SORs: the RMI Responsible Minerals Assurance Process (“RMAP”), the London Bullion Market Association Responsible Gold Guidance and the Responsible Jewelry Council Chain-of-Custody Standard. If the SOR was not certified by these internationally-recognized schemes, Provider attempted to contact the SOR to encourage their participation with the RMI’s RMAP or a cross-recognized program. Additionally, communications were sent to suppliers to encourage them to engage with smelters and refiners that have not been audited and encourage these smelters to undergo an independent third-party audit (e.g., RMAP or equivalent).
f.Attached to this Conflict Minerals Report as Attachment A is a list of the 134 smelters with valid smelter certification numbers identified by our suppliers that provided product specific information; a list of the products covered by this Conflict Minerals Report; and a list of countries of origin associated with these smelters for the metals that are necessary to the production of our products. For the remainder of Spectrum’s Fiscal Year 2024, Spectrum plans to continue to emphasize to its suppliers the importance of sourcing responsibly and from conflict-free sources if the suppliers desire to retain Spectrum’s business

Pursuant to SEC rules and guidance, this Conflict Minerals Report was not subjected to an independent private sector audit.

Spectrum’s review of its Conflict Minerals Report for January 1, 2022 through December 31, 2022 (“Calendar Year 2022”) found that Spectrum had included African Gold Refinery among the smelters in its supply chain.  The inclusion of African Gold Refinery in Spectrum’s Conflict Minerals Report for Calendar Year 2022 was in error; Spectrum has not and does not knowingly source any conflict minerals from African Gold Refinery within its global supply chain.



Attachment A

List of Products

The following products are more fully described in Spectrum Brands Holdings, Inc. Form 10-K, which may be found publicly on our website at: https://investor.spectrumbrands.com/sec-spectrum-brands-holdings-inc

·Electric shavers and accessories
·Grooming products and hair care appliances
·Small household appliances
·Personal care products
·Home improvement and plumbing products
·Residential locksets
·Builders’ hardware
·Insecticides and repellants
·Specialty pet supplies
·Household cleaning products



List of Identified Smelters

Metal Standard Smelter Name Country Location Smelter ID
Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. CHINA CID001622
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation CHINA CID002224
Gold Heraeus Metals Hong Kong Ltd. CHINA CID000707
Gold Kennecott Utah Copper LLC UNITED STATES OF AMERICA CID000969
Gold Metalor Technologies (Suzhou) Ltd. CHINA CID001147
Gold Western Australian Mint (T/a The Perth Mint) AUSTRALIA CID002030
Gold Matsuda Sangyo Co., Ltd. JAPAN CID001119
Gold Mitsubishi Materials Corporation JAPAN CID001188
Gold Heraeus Germany GmbH Co. KG GERMANY CID000711
Gold Tanaka Kikinzoku Kogyo K.K. JAPAN CID001875
Gold Asahi Refining USA Inc. UNITED STATES OF AMERICA CID000920
Gold Aida Chemical Industries Co., Ltd. JAPAN CID000019
Gold Asahi Pretec Corp. JAPAN CID000082
Gold Ishifuku Metal Industry Co., Ltd. JAPAN CID000807
Gold JX Nippon Mining & Metals Co., Ltd. JAPAN CID000937
Gold Kojima Chemicals Co., Ltd. JAPAN CID000981
Gold Mitsui Mining and Smelting Co., Ltd. JAPAN CID001193
Gold Nihon Material Co., Ltd. JAPAN CID001259
Gold Sumitomo Metal Mining Co., Ltd. JAPAN CID001798
Gold Tokuriki Honten Co., Ltd. JAPAN CID001938
Gold AngloGold Ashanti Corrego do Sitio Mineracao BRAZIL CID000058
Gold Argor-Heraeus S.A. SWITZERLAND CID000077
Gold Asahi Refining Canada Ltd. CANADA CID000924
Gold Asaka Riken Co., Ltd. JAPAN CID000090
Gold Aurubis AG GERMANY CID000113
Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) PHILIPPINES CID000128
Gold C. Hafner GmbH + Co. KG GERMANY CID000176
Gold CCR Refinery - Glencore Canada Corporation CANADA CID000185
Gold Chimet S.p.A. ITALY CID000233
Gold Dowa JAPAN CID000401
Gold Eco-System Recycling Co., Ltd. East Plant JAPAN CID000425
Gold Heimerle + Meule GmbH GERMANY CID000694
Gold Istanbul Gold Refinery TURKEY CID000814
Gold Jiangxi Copper Co., Ltd. CHINA CID000855
Gold Metalor Technologies (Hong Kong) Ltd. CHINA CID001149
Gold Metalor Technologies (Singapore) Pte., Ltd. SINGAPORE CID001152
Gold Metalor Technologies S.A. SWITZERLAND CID001153
Gold Metalor USA Refining Corporation UNITED STATES OF AMERICA CID001157
Gold Metalurgica Met-Mex Penoles S.A. De C.V. MEXICO CID001161
Gold Nadir Metal Rafineri San. Ve Tic. A.S. TURKEY CID001220
Gold NH Recytech Company KOREA, REPUBLIC OF CID003189





Metal Standard Smelter Name Country Location Smelter ID
Gold Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH AUSTRIA CID002779
Gold Ohura Precious Metal Industry Co., Ltd. JAPAN CID001325
Gold PT Aneka Tambang (Persero) Tbk INDONESIA CID001397
Gold PX Precinox S.A. SWITZERLAND CID001498
Gold Rand Refinery (Pty) Ltd. SOUTH AFRICA CID001512
Gold Royal Canadian Mint CANADA CID001534
Gold SEMPSA Joyeria Plateria S.A. SPAIN CID001585
Gold Sichuan Tianze Precious Metals Co., Ltd. CHINA CID001736
Gold Solar Applied Materials Technology Corp. TAIWAN, PROVINCE OF CHINA CID001761
Gold Umicore S.A. Business Unit Precious Metals Refining BELGIUM CID001980
Gold United Precious Metal Refining, Inc. UNITED STATES OF AMERICA CID001993
Gold Valcambi S.A. SWITZERLAND CID002003
Gold Yamakin Co., Ltd. JAPAN CID002100
Gold Yokohama Metal Co., Ltd. JAPAN CID002129
Tantalum TANIOBIS Smelting GmbH & Co. KG GERMANY CID002550
Tantalum TANIOBIS Co., Ltd. THAILAND CID002544
Tantalum Materion Newton Inc. UNITED STATES OF AMERICA CID002548
Tantalum TANIOBIS Japan Co., Ltd. JAPAN CID002549
Tantalum Mitsui Mining and Smelting Co., Ltd. JAPAN CID001192
Tantalum Global Advanced Metals Boyertown UNITED STATES OF AMERICA CID002557
Tantalum Global Advanced Metals Aizu JAPAN CID002558
Tantalum Ulba Metallurgical Plant JSC KAZAKHSTAN CID001969
Tantalum Ningxia Orient Tantalum Industry Co., Ltd. CHINA CID001277
Tantalum Taki Chemical Co., Ltd. JAPAN CID001869
Tantalum D Block Metals, LLC UNITED STATES OF AMERICA CID002504
Tantalum F&X Electro-Materials Ltd. CHINA CID000460
Tantalum FIR Metals & Resource Ltd. CHINA CID002505
Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. CHINA CID002492
Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. CHINA CID000914
Tantalum Jiujiang Tanbre Co., Ltd. CHINA CID000917
Tantalum Metallurgical Products India Pvt., Ltd. INDIA CID001163
Tantalum NPM Silmet AS ESTONIA CID001200
Tantalum AMG Brasil BRAZIL CID001076
Tantalum Mineracao Taboca S.A. BRAZIL CID001175
Tantalum Telex Metals UNITED STATES OF AMERICA CID001891
Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. CHINA CID002158
Tin Malaysia Smelting Corporation (MSC) MALAYSIA CID001105
Tin PT Timah Tbk Mentok INDONESIA CID001482
Tin Tin Smelting Branch of Yunnan Tin Co., Ltd. CHINA CID002180





Metal Standard Smelter Name Country Location Smelter ID
Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. CHINA CID000538
Tin China Tin Group Co., Ltd. CHINA CID001070
Tin Metallic Resources, Inc. UNITED STATES OF AMERICA CID001142
Tin Tin Technology & Refining UNITED STATES OF AMERICA CID003325
Tin PT Timah Tbk Kundur INDONESIA CID001477
Tin Thaisarco THAILAND CID001898
Tin Minsur PERU CID001182
Tin Mineracao Taboca S.A. BRAZIL CID001173
Tin PT Bangka Serumpun INDONESIA CID003205
Tin PT Refined Bangka Tin INDONESIA CID001460
Tin Dowa JAPAN CID000402
Tin Mitsubishi Materials Corporation JAPAN CID001191
Tin PT Mitra Stania Prima INDONESIA CID001453
Tin O.M. Manufacturing Philippines, Inc. PHILIPPINES CID002517
Tin Aurubis Beerse BELGIUM CID002773
Tin Aurubis Berango SPAIN CID002774
Tin Chifeng Dajingzi Tin Industry Co., Ltd. CHINA CID003190
Tin Fenix Metals POLAND CID000468
Tin Guangdong Hanhe Non-Ferrous Metal Co., Ltd. CHINA CID003116
Tin Jiangxi New Nanshan Technology Ltd. CHINA CID001231
Tin Magnu's Minerais Metais e Ligas Ltda. BRAZIL CID002468
Tin O.M. Manufacturing (Thailand) Co., Ltd. THAILAND CID001314
Tin Resind Industria e Comercio Ltda. BRAZIL CID002706
Tin White Solder Metalurgia e Mineracao Ltda. BRAZIL CID002036
Tungsten A.L.M.T. Corp. JAPAN CID000004
Tungsten Xiamen Tungsten Co., Ltd. CHINA CID002082
Tungsten Wolfram Bergbau und Hutten AG AUSTRIA CID002044
Tungsten Xiamen Tungsten (H.C.) Co., Ltd. CHINA CID002320
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. CHINA CID000258
Tungsten Ganzhou Seadragon W & Mo Co., Ltd. CHINA CID002494
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. CHINA CID002551
Tungsten Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch CHINA CID002513
Tungsten Guangdong Xianglu Tungsten Co., Ltd. CHINA CID000218
Tungsten H.C. Starck Tungsten GmbH GERMANY CID002541
Tungsten Hunan Jintai New Material Co., Ltd. CHINA CID000769
Tungsten Japan New Metals Co., Ltd. JAPAN CID000825
Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. CHINA CID002318
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. CHINA CID002317
Tungsten Kennametal Huntsville UNITED STATES OF AMERICA CID000105
Tungsten Masan High-Tech Materials VIET NAM CID002543
Tungsten Niagara Refining LLC UNITED STATES OF AMERICA CID002589
Tungsten TANIOBIS Smelting GmbH & Co. KG GERMANY CID002542
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. CHINA CID002315





Metal Standard Smelter Name Country Location Smelter ID
Tungsten Hunan Chenzhou Mining Co., Ltd. CHINA CID000766
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. CHINA CID002321
Tungsten Kennametal Fallon UNITED STATES OF AMERICA CID000966