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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT

COLGATE-PALMOLIVE COMPANY
(Exact name of the registrant as specified in its charter)


Delaware1-64413-1815595
(State or Other Jurisdiction
of Incorporation)		(Commission
File Number)		 (IRS Employer
Identification No.)
300 Park Avenue, New York, NY10022
 (Address of Principal Executive Offices)(Zip Code)


Henning I. Jakobsen
Chief Financial Officer
(212) 310-2000
(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:

x Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the
reporting period from January 1 to December 31, 2019.




Section 1 – Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

Colgate-Palmolive Company (the “Company”) has filed this Specialized Disclosure Form (Form SD) (including the Conflict Minerals Report) for the year ended December 31, 2019 to comply with Rule 13p-1 under the Securities Exchange Act of 1934 relating to “conflict minerals.” This report is also available in the “For Investors” section of the Company’s website at https://www.colgatepalmolive.com. The reference to the Company’s website is provided for convenience only, and its contents are not incorporated by reference into this Specialized Disclosure Form (Form SD) nor deemed filed with the U.S. Securities and Exchange Commission.

Item 1.02 Exhibit

The Company’s Conflict Minerals Report for the year ended December 31, 2019 is filed as Exhibit 1.01 of this Specialized Disclosure Form (Form SD).

Section 2 – Exhibits

Item 2.01 Exhibits

Exhibit 1.01 Conflict Minerals Report of Colgate-Palmolive Company, as required by Items 1.01 and 1.02 of this Specialized Disclosure Form (Form SD).




SIGNATURE

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.


              
COLGATE-PALMOLIVE COMPANY
Date:           May 29, 2020By:/s/ Henning I. Jakobsen
 Name:Henning I. Jakobsen
 Title:Chief Financial Officer



Document

Colgate-Palmolive Company
Conflict Minerals Report
for the Year Ended December 31, 2019
This Conflict Minerals Report for the year ended December 31, 2019 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 relating to “conflict minerals” (the “Rule”). For purposes of the Rule, “conflict minerals” are limited to cassiterite, columbite-tantalite, wolframite and gold, including their derivatives, which are limited to tin, tantalum and tungsten.
Introduction
Colgate-Palmolive Company (the “Company”) is a leading consumer products company whose products are marketed in over 200 countries and territories throughout the world. As a result of the Company’s global operations, its supply chain sources materials, finished products and services globally and from a large number of suppliers. The Company does not typically source any minerals, including conflict minerals, directly from mines, smelters or refiners and is several supply chain levels removed from these market activities.

The Company manufactures and markets a wide array of oral care, personal care, home care and pet nutrition products. As required by the Rule, the Company has conducted a review of its products to determine whether they contain conflict minerals that are necessary to their functionality or production. Only a small number of the Company’s products were determined to contain necessary conflict minerals. The Company determined that necessary conflict minerals were contained in components of its electric and battery toothbrushes and its whitening tray and certain other oral care devices.

Reasonable Country of Origin Inquiry
As required by the Rule, the Company conducted a reasonable country of origin inquiry into its supply chain to determine whether any of the conflict minerals contained in its products originated in the Democratic Republic of Congo or adjoining countries (collectively, the “Covered Countries”).
Supplier Survey
The Company identified its materials and products that contain necessary conflict minerals by reviewing its reasonable country of origin inquiry survey results from the prior year, searching its product formula database and interviewing internal product ingredient experts. The Company requested that each of the suppliers of these materials and/or products complete the Conflict Minerals Reporting Template developed by the Responsible Minerals Initiative (“RMI”). Responses were reviewed for consistency and completeness, and follow-up inquiries were conducted if necessary. The results of the supplier survey were discussed with members of senior management.
Results of Survey
The Company received responses from 100% of the surveyed suppliers. All but one of the surveyed suppliers indicated that the smelters in their supply chains do not source conflict minerals from the Covered Countries. As of May 15, 2020, all but one of the smelters identified by the surveyed suppliers, including the smelters that source conflict minerals from the Covered Countries, were listed as conforming to RMI’s Responsible Minerals Assurance Process (“RMAP”) assessment protocols, meaning they either had a currently valid audit or a re-audit in progress. The one remaining smelter is not listed as a participant in RMI’s assessment protocols.

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Due Diligence Process
The Company has exercised due diligence on its supply chain, with the goal of determining that the necessary conflict minerals contained in its products did not directly or indirectly finance or benefit armed groups in the Covered Countries. The Company designed its due diligence process to comply in all substantive respects to the framework set forth in the Organization for Economic Cooperation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Framework”).
The Company performed the following due diligence steps:
(1)Establish strong company management systems
•The Company has adopted a conflict minerals policy, which includes information on how to contact the Company for further information and/or to report concerns. The policy is available in the “Sustainability” section of the Company’s website at https://www.colgatepalmolive.com.
•The Company has incorporated its conflict minerals policy into its Third Party Code of Conduct, which conveys the Company’s expectations regarding ethical conduct to all third parties with whom the Company does business.
•The Company has established a team comprised of employees from its procurement, legal and sustainability functions to design and implement its conflict minerals compliance efforts with senior executive level support and oversight.
•The Company has provided background information and training on the Rule to employees involved in its conflict minerals compliance efforts.
•The Company requested relevant suppliers to identify the smelters of the conflict minerals in their materials or products.
•The Company requires that conflict materials documentation be retained for six years pursuant to the Company’s document retention policy.

(2)Identify and assess risks in the supply chain
•As described above under “Reasonable Country of Origin Inquiry,” in order to determine the mine or location of origin of the conflict minerals in the Company’s supply chain with the greatest possible specificity, the Company requested its relevant suppliers to complete the Conflict Minerals Reporting Template developed by RMI.
•The Company reviewed the supplier responses for inconsistent and/or incomplete responses that might indicate a potential risk.
•The Company compared the smelters identified by its suppliers against the RMAP’s lists of compliant and active smelters.

(3)Design and implement a strategy to respond to identified risks
The Company implemented a risk management plan designed to identify, monitor and mitigate identified risks. Elements of the plan included:
•providing updates to senior management in the finance, supply chain and legal functions;
•sending corrective action follow-up notices to suppliers who provided incomplete and/or inconsistent responses to the Company’s information requests;
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•informing relevant suppliers, including new suppliers during the onboarding process, about the Company’s conflict minerals policy; and
•encouraging suppliers who provided inconsistent or incomplete responses to improve their due diligence practices in accordance with the Company’s conflict minerals policy.

(4)Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain
The Company does not conduct audits of smelters. The Company relies on the RMAP to audit smelters that may be in the Company’s supply chain. If a surveyed supplier identifies a smelter that is not listed as compliant with RMAP’s assessment protocols, the Company follows up with the supplier for additional information and further action.
(5)Report on supply chain due diligence
This Conflict Minerals Report and the Company’s Specialized Disclosure Report (Form SD) are available in the “For Investors” section of the Company’s website at https://www.colgatepalmolive.com. The reference to the Company’s website is provided for convenience only, and its contents are not incorporated by reference into this Conflict Minerals Report nor deemed filed with the U.S. Securities and Exchange Commission.
Smelters
Attached as an Annex to this Conflict Minerals Report is an aggregated list of the smelters reported to the Company by its suppliers of conflict minerals. Some of the suppliers that provided this information did so either on a company or division level, and not in relation to specific products. Therefore, the Company is unable to determine whether many of these smelters are actually in the Company’s supply chain.
Ongoing Risk Mitigation Efforts
The Company has implemented an ongoing risk mitigation plan that is intended to strengthen its supply chain due diligence capability and traceability with respect to conflict minerals and reduce the risk that the sourcing of any conflict minerals benefits armed groups in the Covered Countries. The Company’s ongoing risk mitigation efforts include:
•incorporating supplier contract language and/or terms and conditions that require relevant suppliers to cooperate with the Company’s conflict minerals compliance efforts;
•continuing to engage with the Company’s suppliers, including new suppliers, to develop and enhance their due diligence processes; and
•sharing the Company’s conflict minerals policy with suppliers.

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Cautionary Statement on Forward-Looking Statements
This Conflict Minerals Report, including the description of the Company’s ongoing risk mitigation efforts, contains forward-looking statements (as such term is defined in the Private Securities Litigation Reform Act of 1995 or by the Securities and Exchange Commission in its rules, regulations and releases). These statements are made on the basis of the Company’s views and expectations as of this time and the Company undertakes no obligation to update these statements whether as a result of new information, future events or otherwise, except as required by law or by the rules and regulations of the Securities and Exchange Commission. The Company cautions investors that such forward-looking statements are not guarantees of future performance and that actual events or results may differ materially from those statements due to factors, such as the implementation of satisfactory traceability and other compliance measures by the Company’s direct and indirect suppliers on a timely basis or at all, whether smelters and refiners and other market participants responsibly source conflict minerals, internal and external resource restraints, and political and regulatory developments, whether in the Covered Countries, the United States or elsewhere. For a description of certain factors that could cause the Company’s future events or results to differ materially from those expressed in any forward-looking statement, please refer to the Company’s filings with the Securities and Exchange Commission, including, without limitation, information under captions “Risk Factors” and “Cautionary Statement on Forward-Looking Statements” included in the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2019 and subsequent Quarterly Reports on Form 10-Q.

Annex
Smelters
MetalSmelter IDSmelter NameSmelter Location
RMAP Status (1)(*)
GoldCID001193Mitsui Mining and Smelting Co., Ltd.JAPANCompliant
GoldCID001622Shandong Zhaojin Gold & Silver Refinery Co., Ltd.CHINACompliant
GoldCID002224Zhongyuan Gold Smelter of Zhongjin Gold CorporationCHINACompliant
TantalumCID000092Asaka Riken Co., Ltd.JAPANCompliant
TantalumCID000211Changsha South Tantalum Niobium Co., Ltd.CHINACompliant
TantalumCID000291Guangdong Rising Rare Metals-EO Materials Ltd.CHINACompliant
TantalumCID000456Exotech Inc.UNITED STATES OF AMERICACompliant
TantalumCID000460F&X Electro-Materials Ltd.CHINACompliant
TantalumCID000914JiuJiang JinXin Nonferrous Metals Co., Ltd.CHINACompliant
TantalumCID000917Jiujiang Tanbre Co., Ltd.CHINACompliant
TantalumCID001076LSM Brasil S.A.BRAZILCompliant
TantalumCID001163Metallurgical Products India Pvt., Ltd.INDIACompliant
TantalumCID001175Mineração Taboca S.A.BRAZILCompliant
TantalumCID001192Mitsui Mining and Smelting Co., Ltd.JAPANCompliant
TantalumCID001200NPM Silmet ASESTONIACompliant
TantalumCID001277Ningxia Orient Tantalum Industry Co., Ltd.CHINACompliant
TantalumCID001508QuantumCleanUNITED STATES OF AMERICACompliant
TantalumCID001522Yanling Jincheng Tantalum & Niobium Co., Ltd.CHINACompliant
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MetalSmelter IDSmelter NameSmelter Location
RMAP Status (1)(*)
TantalumCID001769Solikamsk Magnesium Works OAORUSSIAN FEDERATIONCompliant
TantalumCID001869Taki Chemical Co., Ltd.JAPANCompliant
TantalumCID001891Telex MetalsUNITED STATES OF AMERICACompliant
TantalumCID001969Ulba Metallurgical Plant JSCKAZAKHSTANCompliant
TantalumCID002492Hengyang King Xing Lifeng New Materials Co., Ltd.CHINACompliant
TantalumCID002504D Block Metals, LLCUNITED STATES OF AMERICACompliant
TantalumCID002505FIR Metals & Resource Ltd.CHINACompliant
TantalumCID002506Jiujiang Zhongao Tantalum & Niobium Co., Ltd.CHINACompliant
TantalumCID002508XinXing HaoRong Electronic Material Co., Ltd.CHINACompliant
TantalumCID002512Jiangxi Dinghai Tantalum & Niobium Co., Ltd.CHINACompliant
TantalumCID002539KEMET Blue MetalsMEXICOCompliant
TantalumCID002544H.C. Starck Co., Ltd.THAILANDCompliant
TantalumCID002545H.C. Starck Tantalum and Niobium GmbHGERMANYCompliant
TantalumCID002547H.C. Starck Hermsdorf GmbHGERMANYCompliant
TantalumCID002548H.C. Starck Inc.UNITED STATES OF AMERICACompliant
TantalumCID002549H.C. Starck Ltd.JAPANCompliant
TantalumCID002550H.C. Starck Smelting GmbH & Co. KGGERMANYCompliant
TantalumCID002557Global Advanced Metals BoyertownUNITED STATES OF AMERICACompliant
TantalumCID002558Global Advanced Metals AizuJAPANCompliant
TantalumCID002568KEMET Blue PowderUNITED STATES OF AMERICACompliant
TantalumCID002707Resind Industria e Comercio Ltda.BRAZILCompliant
TantalumCID002842Jiangxi Tuohong New Raw MaterialCHINACompliant
TantalumCID002847Power Resources Ltd.MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OFCompliant
TantalumCID003191Jiujiang Janny New Material Co., Ltd.CHINA*
TinCID000309PT Aries Kencana SejahteraINDONESIACompliant
TinCID000315CV United SmeltingINDONESIACompliant
TinCID000438EM VintoBOLIVIA (PLURINATIONAL STATE OF)Compliant
TinCID000942Kaimeng (Gejiu) Industry and Trade Co., Ltd.CHINACompliant
TinCID001070China Tin Group Co., Ltd.CHINACompliant
TinCID001105Malaysia Smelting Corporation (MSC)MALAYSIACompliant
TinCID001173Mineração Taboca S.A.BRAZILCompliant
TinCID001182MinsurPERUCompliant
TinCID001191Mitsubishi Materials CorporationJAPANCompliant
TinCID001337Operaciones Metalurgicas S.A.BOLIVIA (PLURINATIONAL STATE OF)Compliant
TinCID001419PT Bangka Tin IndustryINDONESIACompliant
TinCID001421PT Belitung Industri SejahteraINDONESIACompliant
TinCID001428PT Bukit TimahINDONESIACompliant
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MetalSmelter IDSmelter NameSmelter Location
RMAP Status (1)(*)
TinCID001434PT DS Jaya AbadiINDONESIACompliant
TinCID001453PT Mitra Stania PrimaINDONESIACompliant
TinCID001457PT Panca Mega PersadaINDONESIACompliant
TinCID001458PT Prima Timah UtamaINDONESIACompliant
TinCID001460PT Refined Bangka TinINDONESIACompliant
TinCID001463PT Sariwiguna BinasentosaINDONESIACompliant
TinCID001468PT Stanindo Inti PerkasaINDONESIACompliant
TinCID001471PT Sumber Jaya IndahINDONESIACompliant
TinCID001477PT Timah Tbk KundurINDONESIACompliant
TinCID001482PT Timah Tbk MentokINDONESIACompliant
TinCID001490PT Tinindo Inter NusaINDONESIACompliant
TinCID001493PT Tommy UtamaINDONESIACompliant
TinCID001539Rui Da HungTAIWANCompliant
TinCID001898ThaisarcoTHAILANDCompliant
TinCID002036White Solder Metalurgia e Mineracao Ltda.BRAZILCompliant
TinCID002158Yunnan Chengfeng Non-ferrous Metals Co., Ltd.CHINACompliant
TinCID002180Yunnan Tin Company LimitedCHINACompliant
TinCID002455CV Venus Inti PerkasaINDONESIACompliant
TinCID002592CV Dua SekawanINDONESIACompliant
TinCID002593PT Rajehan AriqINDONESIACompliant
TinCID002773Metallo Belgium N.V.BELGIUMCompliant
TinCID002776PT Bangka Prima TinINDONESIACompliant
TinCID002816PT Sukses Inti MakmurINDONESIACompliant
TinCID002835PT Menara Cipta MuliaINDONESIACompliant
TinCID003116Guangdong Hanhe Non-Ferrous Metal Co., Ltd.CHINACompliant
TinCID003205PT Bangka SerumpunINDONESIACompliant
TinCID003325Tin Technology & RefiningUNITED STATES OF AMERICACompliant
TungstenCID002082Xiamen Tungsten Co., Ltd.CHINACompliant
(1) Smelters identified as “Compliant” are listed as complying with the RMAP assessment protocols (as of May 15, 2020) and include (i) smelters with currently valid audits and (ii) smelters with re-audits in progress
* Smelter is not listed as a participant in RMI’s assessment protocols (as of May 15, 2020)
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