GMCR (MM)

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

Specialized Disclosure Report

KEURIG GREEN MOUNTAIN, INC.

(Exact name of registrant as specified in its charter)

33 Coffee Lane, Waterbury, Vermont 05676

(Address of registrant’s principal executive office) (Zip Code)

Michael J. Degnan
(781) 418-3120

(Name and telephone number, including area code, of 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 applies:

x   Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2014

Section 1 — Conflict Minerals Disclosure

Item 1.01  Conflict Minerals Disclosure and Report

Conflict Minerals Disclosure

This Form SD of Keurig Green Mountain, Inc. (the “Company” or “Keurig”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2014 to December 31, 2014.

A copy of the Company’s Conflict Minerals Report is provided as Exhibit 1.01 to this Form SD, and is publicly available at http://www.keuriggreenmountain.com/Sustainability/ReportsAndDisclosures/ConflictMinerals.aspx.

Item 1.02  Exhibit

As specified in Section 2, Item 2.01 of this Form SD, the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this report.

Section 2 — Exhibits

Item 2.01  Exhibits

The following exhibit is filed as part of this report.

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SIGNATURES

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.

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EXHIBIT INDEX

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Exhibit 1.01

Keurig Green Mountain, Inc.

Conflict Minerals Report

For the reporting period from January 1, 2014 to December 31, 2014

Introduction

Keurig Green Mountain, Inc. (the “Company” or “Keurig”) has prepared this Conflict Minerals Report (this “Report”) pursuant to Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2014 to December 31, 2014.

This Report describes our due diligence process and compliance with Rule 13p-1 requirements.  The Rule requires disclosure of certain information when a company manufactures, or contracts to manufacture, products which contain any of the minerals specified in the Rule, if those minerals are necessary to the functionality or production of such products.  The specified minerals, which the Company collectively refer to in this Report as “3TG”, are gold, columbite-tantalite (coltan), cassiterite and wolframite and their derivatives, which are limited to tantalum, tin and tungsten.  The “Covered Countries” for the purposes of the Rule and this Report are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.

As described in this Report, certain 3TG are necessary to the functionality or production of products that the Company contracted to manufacture in calendar year 2014.  These products are Keurig’s hot beverage system brewers (the “Covered Products”). (1)  Third-party products that Keurig retails but that it does not manufacture or contract to manufacture are outside of the scope of this Report.

The Company has in good faith conducted a reasonable country of origin inquiry regarding 3TG.  This country of origin inquiry was designed to determine whether any of the 3TG used in the Covered Products originated in the Covered Countries and whether any of such 3TG may be from recycled or scrap sources.  The Company also performed due diligence on the source and chain of custody of such 3TG as described in more detail below.

Keurig’s due diligence process is based on the Organization for Economic Cooperation and Development’s (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and accompanying Supplements (the “OECD Guidance”).(2)

Keurig Conflict Minerals Policy

The Company has adopted a policy relating to 3TG incorporating the standards set forth in the OECD Guidance (the “Company Conflict Minerals Policy”) in its Responsible Sourcing Supplier

(1)  Does not include (i) MDS Global Holding p.l.c. (“Bevyz”) products in accordance with Instruction 3 to Item 1.01 of Form SD, or (ii) pods (K-Cup®, Vue®, Rivo®, K-Carafe™ and Bolt™ pods) in accordance with the SEC’s Dodd-Frank Wall Street Reform and Consumer Protection Act, Frequently Asked Questions, #6.

(2)  OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Supplement on Tin, Tantalum and Tungsten and Supplement on Gold, 2013; http://www.oecd.org/daf/inv/mne/GuidanceEdition2.pdf.

Guidelines.  All of Keurig’s suppliers are required to adhere to its Responsible Sourcing Supplier Guidelines, which are available on its website at www.KeurigGreenMountain.com/SupplierGuidelines.

The Company Conflict Minerals Policy states in part that the Company is committed to: (1) supporting the aims and objectives of the U.S. legislation on the disclosure of 3TG; (2) not knowingly procuring 3TG that originates from facilities in the Covered Countries that are not certified as “conflict free”; and (3) ensuring compliance with the Company Policy.

Reasonable Country of Origin Inquiry

Keurig identified its suppliers of the Covered Products with whom it contracts directly (the “Tier 1 Suppliers”), and requested each submit information to Keurig using the Conflict Free Sourcing Initiative (“CFSI”) Conflict Minerals Reporting Template (the “CMRT”).  The CMRT is a survey tool developed by the CFSI to standardize collection of due diligence information in the supply chain.

The information submitted by Keurig’s Tier 1 Suppliers in the CMRTs included information gathered by those suppliers about the smelters and refiners identified in their own supply chains which Keurig utilized to conduct further due diligence.  As described in more detail below, Keurig’s responsible sourcing team reviewed each CMRT for completeness and performed a red flag analysis on each CMRT received.

Based on the information provided and Keurig’s due diligence efforts, as described in more detail below, Keurig is not able to conclusively determine all of the countries of origin of the 3TG in its products or whether the 3TG in its products are from recycled or scrap sources.

Due Diligence

Design of Due Diligence

Keurig designed its due diligence measures in accordance with the OECD Guidance, and the related supplements on 3TG.

The OECD Guidance utilizes a five-step process for due diligence:

Step 1:  Establish Strong Company Management Systems

Step 2:  Identify and Assess Risks in the Supply Chain

Step 3:  Design and Implement a Strategy to Respond to Identified Risks

Step 4:  Carry Out Independent Third-Party Audit of Smelters’ and Refiners’ Due Diligence Practices

Step 5:  Report Annually on Supply Chain Due Diligence

Keurig intends to retain conflict minerals documentation materials for five years after receipt.

Below is a description of Keurig’s due diligence measures performed for the 2014 reporting year.

Due Diligence Measures Performed

Members from the Company’s procurement, legal, and sustainability teams were involved in the due diligence process, which was led by the Company’s responsible sourcing team.

Keurig has begun establishing a system of controls and transparency to determine the smelters and refiners in its 3TG supply chain by creating a process to engage Tier 1 Suppliers.  Keurig has also begun incorporating requirements related to conflict minerals and related due diligence activities in supplier contracts.

As described above, as part of its due diligence process Keurig requested that each Tier 1 Supplier submit a completed CMRT.  Keurig also provided its Tier 1 Suppliers with links to publicly available training resources, and engaged in ongoing communication and provided support to its Tier 1 Suppliers to facilitate their completion of the CMRTs.  To monitor and track performance of risk management efforts, Keurig relies on supplier CMRTs and updates of the CFSI’s Conflict Free Smelters Program (CFSP).  Only one Tier 1 Supplier did not submit a CMRT, and for that Tier 1 Supplier the Company has sent follow-up inquiries to solicit their response and offered assistance.

A key element of responding to identified risks was to review the nature and overall risk of supplier responses received.  The Company’s responsible sourcing team reviewed each CMRT for completeness and performed a red flag analysis on each CMRT received.  This red flag analysis consisted of 10 logical tests to review supplier answers to questions contained in the CMRT for completeness and consistency.  Responses that failed a minimum of one red flag review test were singled out for additional follow-up, and a member of the Company’s responsible sourcing team contacted such suppliers directly to obtain additional information and/or clarify inconsistent responses in order to assess the risk.

For Tier 1 Suppliers that indicated in their responses that they or a supplier in their supply chain did use 3TG in their part(s) and/or product(s) during calendar year 2014 and provided the applicable smelter or refiner information, the Company reconciled the reported smelters and refiners against the CFSI’s Conflict Free Smelters List (available at www.conflictfreesourcing.org) as of May 6, 2015.

Beginning in 2014, Keurig reports annually on supply chain due diligence by filing with the SEC a Form SD and Conflict Minerals Report.

Due Diligence Results

Based on the information that was provided by the Company’s suppliers and otherwise obtained through the due diligence process, Keurig validated that 225 facilities are “known” based on the CFSI’s Smelter Reference List in the CMRT version 3.02.  Keurig reasonably determined that facilities used to process the 3TG contained in Keurig products included 144 smelters and refiners were verified as compliant with the CFSI’s Conflict Free Smelters Program (CFSP). (3)

(3)  CFSI’s Conflict Free Smelters Program List as of May 6, 2015

Based on the information that was provided by the Company’s suppliers and otherwise obtained through the due diligence process, 81 of the identified smelters and refiners were not verified as CFSP compliant. (4)  A list of all 225 of the smelters and refiners identified during the due diligence process is included in Annex I to this Report.  An additional thirty-seven entities were included on the CMRTs but are not recognized as smelters or refiners on the CFSI’s Smelter Reference List in the CMRT version 3.02, (5) and are therefore not included in either this summary or on Annex I hereto.

Risk Mitigation and Future Due Diligence Measures

Keurig plans to continue to improve its due diligence measures by taking the following steps, among others:

·                  continuing to engage with suppliers to obtain current, accurate and complete information about our supply chain, encourage them to continue building up their due diligence process, and endeavor to continue incorporating provisions relating to “conflict-free” sourcing and reporting into the applicable contracts;

·                  encouraging suppliers to implement responsible sourcing and to have them encourage smelters and refiners to obtain a “conflict-free” designation from an independent, third-party auditor;

·                  further automating our survey review process to more efficiently track and analyze the information received and identify what information is still missing or requires follow-up;

·                  benchmarking our progress against our peers;

·                  building out the Conflict Minerals team to include more cross-functional members; and

·                  continuing to evaluate the Company’s due diligence measures against the OECD guidance to identify gaps in our program and opportunities for improvement.

Determination

Based on the information obtained pursuant to the due diligence process described above, Keurig believes that the facilities that may have been used to process the 3TG in Keurig products include the smelters and refiners listed in Annex I below.  However, Keurig is not able to conclusively determine all of the countries of origin of the 3TG in its products or whether the 3TG in its products are from recycled or scrap sources.

Keurig has provided information as of the date of this Report.  Subsequent events, such as the inability or unwillingness of any suppliers, smelters or refiners to comply with Keurig’s Conflict Minerals Policy, may affect Keurig’s future determinations under the Rule.

(4)  CFSI’s Conflict Free Smelters Program List as of May 6, 2015

(5)  CFSI’s Conflict Free Smelters Program List as of May 6, 2015

ANNEX I

List of Smelter Facilities

The table below represents a consolidated list of smelters (225 in total) identified by Keurig’s Tier 1 Suppliers.  The results are based on:

·                  Information provided by Keurig’s Tier 1 Suppliers in their CMRTs; and

·                  The CFSI’s Conflict Free Smelters Program List as of May 6, 2015

(6)  As determined by the CFSI’s Conflict Free Smelters Program List as of May 6, 2015