Tupperware Brands (TUPBQ) SDConflict minerals disclosure

Exhibit 1.01

Conflict Minerals Report

for the Year Ended December 31, 2019

SUMMARY

Tupperware Brands Corporation (the “Company”) has filed this report in accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (“Rule 13p-1”). Rule 13p-1 was adopted by the Securities and Exchange Commission (the “SEC”) to implement reporting and disclosure requirements mandated by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Rule 13p-1 imposes reporting obligations on public companies, including the Company, whose manufactured final products contain one or more conflict minerals that are necessary to the functionality or production of such products. For purposes of Rule 13p-1 and the related disclosures, the term “conflict minerals” is defined to include columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten.

The Company identified several products or components of products that contained or might have contained conflict minerals that are necessary to their functionality or production, and accordingly, the Company was required to and did conduct a good faith Reasonable Country of Origin Inquiry (“RCOI”) and additional due diligence to attempt to determine the country or countries of origin and chain of custody of such conflict minerals.

While the Company has not identified the tin contained in one of its products, the Induction Cooking Plate, or the tantalum or tungsten contained in another of its products, the TW-100 Water Ionizer, as having originated from the Democratic Republic of the Congo or adjoining countries (collectively, “Covered Countries”), the Company has not received sufficient information from the supplier of the Induction Cooking Plate or the supplier of the TW-100 Water Ionizer in order to conclude that either product definitively is, or is not, “DRC conflict free.” Accordingly, the Induction Cooking Plate and the TW-100 Water Ionizer are considered “DRC conflict undeterminable,” as defined in applicable SEC rules. These rules define “DRC conflict undeterminable” as a product manufactured or contracted to be manufactured that a company, such as the Company, is unable to determine, after exercising due diligence, whether or not such product qualifies as “DRC conflict free.”

COMPANY OVERVIEW

Tupperware Brands Corporation is a global manufacturer and marketer of innovative, premium household, beauty and personal care products across multiple brands utilizing social selling. Product brands and categories include design-centric preparation, storage and serving solutions for the kitchen and home through the Tupperware® brand and beauty and personal care products through the Avroy Shlain®, Fuller Cosmetics®, NaturCare®, Nutrimetics® and Nuvo® brands. The Company's stock is listed on the New York Stock Exchange (NYSE: TUP). See Part I, Item 1, Business, of the Company’s Form 10-K Annual Report for the year ended December 28, 2019 for additional information.

Product Description

The products determined to be “DRC conflict undeterminable” and covered in this report are (i) the Company’s Induction Cooking Plate, due to the potential source of tin in the product from a smelter located in Rwanda that is not on the RMAP (as defined below) conformant smelters list and (ii) the TW-100 Water Ionizer, due to the potential sources of tantalum and tungsten in the product from three smelters located in the DRC that are not on the RMAP conformant smelters list.

DUE DILIGENCE

Due Diligence Steps Taken

In accordance with the OECD Guidance, the Company’s due diligence measures included the following steps:

Because the Company is several steps removed from the original sources of any conflict minerals contained in its products, the Company relies on its direct suppliers to provide information on the origin of any conflict minerals contained in the products or components of products that they supply. In some instances the Company’s direct suppliers are similarly reliant upon information provided to them by their suppliers. Also, some of the Company’s direct suppliers are not themselves subject to SEC reporting and due diligence requirements, which in some cases increases the difficulty of obtaining information about the original sources of the conflict minerals contained in the products or components of products.

To the best of its knowledge, the Company did not source any conflict minerals directly from mines, smelters or refiners. Consequently, the Company does not have a direct relationship with conflict minerals smelters and refiners, and is unable to perform or direct audits of these entities within the Company’s supply chain.

The Company reviewed the suppliers in its supply chain, and identified suppliers that, during the calendar year 2019, provided it with products or components of products that contained or might have contained conflict minerals. The Company conducted an RCOI by having a member of the Company’s Procurement team and/or local management team, by email and/or telephone, explain to such suppliers the SEC’s requirement that the Company report conflict minerals necessary to the functionality or production of its products or components of products, and request that such suppliers complete the CMRT. The CMRT included questions regarding the supplier’s use and the source of conflict minerals necessary to the functionality or production of the products or components of products supplied, and regarding the supplier’s own policies and due diligence efforts with respect to its suppliers. As necessary, the Company followed up by email and telephone to the suppliers, and offered assistance and further explanations to those suppliers in order to complete the CMRT. Where a supplier or the manufacturer of a product or product component did not complete a CMRT, the Company obtained a written statement from the supplier that any conflict mineral(s) contained in the product or product component did not originate from a Covered Country. The Company reviewed and analyzed the CMRT responses and written statements to interpret the responses and statements, and to determine whether further engagement with any of the suppliers was warranted. The Company requested additional information and/or clarifications (by email and/or telephone) where the CMRT or written statement was incomplete, or where any responses or written statements provided were contradictory or unclear. The Company made repeated additional follow-up efforts, by email and/or telephone, to ensure that the identified suppliers responded to its inquiries.

CMRT and Written Statement Responses

The Company has received responses from the suppliers identified as supplying during 2019 products or components of products that contained or might have contained conflict minerals. After due diligence and analysis, the Company has not been able to determine with reasonable certainty the country or countries of origin or chain of custody of all of the tin necessary to the functionality or production of the Induction Cooking Plate, or all of the tantalum or tungsten necessary to the functionality or production of the TW-100 Water Ionizer. Consequently, the Company has concluded that the Induction Cooking Plate and TW-100 Water Ionizer are “DRC conflict undeterminable” for purposes of this report.

Efforts to Determine Mine or Location of Origin

The Company’s ability to determine the mine or location of origin of the tin necessary to the functionality or production of the Company’s Induction Cooking Plate, and of the tantalum and tungsten necessary to the functionality or production of the TW-100 Water Ionizer, is based upon information the Company has received from the suppliers of such products in its due diligence processes. Despite its good faith efforts, the Company has concluded that these products remain “DRC conflict undeterminable,” due to the fact that it has been unable to determine the country or countries of origin or chain of custody of all of the tin necessary to the functionality or production of the Induction Cooking Plate, or all of the tantalum or tungsten necessary to the functionality or production of the TW-100 Water Ionizer, and consequently all of the facilities used to process such tin, tantalum or tungsten. The Company has attached as Annex I to this Exhibit a copy of the list of smelters provided by the supplier of the Induction Cooking Plate, and as Annex II to this Exhibit a copy of the list of smelters provided by the supplier of the TW-100 Water Ionizer.

Steps the Company Is Taking to Mitigate Risk

The Company has taken, and is taking, the following steps to mitigate the risk that conflict minerals necessary to the functionality or production of its products could benefit armed groups in the DRC or adjoining countries:

Annex II

Smelter List Provided by Supplier of TW-100 Water Ionizer