Conflict Minerals Policy and Report

The Securities and Exchange Commission (the “SEC”) has adopted a conflict minerals rule (the“Conflict Minerals Rule”) in accordance with the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 that requires public companies such as WestRock to annually disclose whether any conflict minerals necessary to the functionality or production of the products it manufactures or contracts to manufacture is sourced from the Democratic Republic of the Congo(the “DRC”) or its adjoining countries. “Conflict minerals,” as defined in the Conflict Minerals Rule, include gold, tin, tantalum and tungsten. The mining and trade of the minerals are believed to help finance armed groups that are committing human rights abuses in the DRC and its adjoining countries. The Conflict Minerals Rule is intended to reduce a significant source of funding for these groups.

Certain WestRock products have been found to contain conflict minerals. Our goal is to use only such minerals that do not directly or indirectly finance or benefit armed groups in the DRC and its adjoining countries.While we do not ban the sourcing of minerals from the DRC and its adjoining countries,we encourage our suppliers who source from that region to only use conflict-free sources.

We perform supply chain due diligence based upon a framework developed by the Organisation for Economic Co-Operation and Development, as required by the Conflict Minerals Rule.Likewise, we expect our suppliers to conduct their own due diligence to determine the sources of conflict minerals used in any products that they supply to us.

Download Conflict Minerals Report PDF