Form: SD

Specialized Disclosure Report filed pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act relating to the use of conflict minerals (Rule 13p-1)

May 20, 2016

Exhibit 1.01


Ball Corporation
Conflict Minerals Report
For the Year Ended December 31, 2015

Introduction

This Conflict Minerals Report ("CMR") for the year ended December 31, 2015, is presented to comply with Rule 13p‑1 under the Securities Exchange Act of 1934 (the "Rule"). The Rule was adopted by the Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the "Dodd-Frank Act"). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. Conflict minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives which are limited to tin, tantalum, tungsten, and gold ("3TG" or "Conflict Minerals"). The reporting and disclosure requirements apply to registrants whatever the geographic origin of the Conflict Minerals and whether or not they fund armed conflict.

Company Overview

This report has been prepared by the Company (herein referred to as "Ball," the "Company," "we," "us," or "our"). The information provided in this CMR includes the activities of all our majority-owned subsidiaries and variable interest entities that are required to be consolidated.

Ball supplies innovative, sustainable packaging solutions for beverage, food and household products customers, as well as aerospace and other technologies and services primarily for the U.S. government. Our principal products include metal packaging for beverage, food and household products, as well as components related to aerospace and other technologies. We conducted an analysis of our products and found that some of our products contain Conflict Minerals that are necessary to their functionality or production.

Initially, we engaged with consultants to assist us with the design and implementation of our due diligence program, and to help establish processes and procedures for the review and validation of supplier responses. We continue to take steps to improve our program over previous years, including refining our due diligence program, and improving engagement with our suppliers to increase our response rates and the quality of responses received.

Reasonable Country of Origin Inquiry

In accordance with the Rule, we conducted in good faith a reasonable country of origin inquiry ("RCOI") designed to determine whether any of the necessary Conflict Minerals in our products originated in the Democratic Republic of the Congo or an adjoining country (the "Covered Countries") or were from recycled or scrap sources.

We used the Conflict Free Sourcing Initiative's ("CFSI") conflict minerals reporting template (the "Reporting Template") to obtain sourcing information from our direct suppliers. Our RCOI included assessing the responses we received from our suppliers in accordance with our due diligence framework.



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Based on our assessment of the responses from our suppliers, we have reason to believe that some of the necessary 3TG used in our products may have originated in a Covered Country and may not have come from recycled or scrap sources.

Due Diligence

1. Design of Due Diligence

Our due diligence program has been designed to conform in all material respects with the framework in The Organisation for Economic Co-operation and Development ("OECD") Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High Risk Areas, and the related Supplements for gold and for tin, tantalum and tungsten (the "OECD Guidance"). Ball took the following steps in accordance with our due diligence program:

a. Establish Strong Company Management Systems

The Company has adopted and made public a conflict minerals policy. Our policy can be found at http://www.ball.com/Ball/media/Ball/Global/Downloads/Ball_Conflict_Minerals_Policy.pdf. This policy is made available to employees through an internal company portal, is publicly available on the Ball website, and is also disseminated to suppliers during our RCOI process. In addition to our conflict minerals policy, Ball has a Ball Business Ethics Handbook (the "Handbook"), which outlines expected behaviors for all of our employees. The Handbook addresses Ball's commitment to compliance with all laws applicable to the way we do business and to social sustainability.

In order to strengthen engagement with suppliers, as part of establishing management systems, we have Supplier Guiding Principles, which are included as an exhibit to our form supplier agreements. The Supplier Guiding Principles, among other things, state our expectation that our suppliers will maintain ethical business practices, including compliance with laws related to human rights. More specifically, in 2015 we continued to include a Conflict Minerals certification as part of our form supplier agreements. Since many of our agreements are long-term contracts, it will take several years for existing agreements to expire and for the Conflict Minerals certification to be included in all supplier agreements.

We utilized the Reporting Template as a tool to collect information from our suppliers regarding the smelters and refiners from which Conflict Minerals in materials and/or components that are supplied to us are derived. We also continue to engage our suppliers through follow-up to improve response quality pursuant to our due diligence program, which includes steps to review responses.

Key management members and subject matter experts implement the due diligence program, including training new employees involved in the due diligence program and conducting Conflict Minerals Working Group meetings as deemed necessary. This group also implements procedures to review supplier responses, engage with suppliers and maintain records.





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b. Identify and Assess Risk in the Supply Chain

We identified suppliers that potentially provide materials and/or components containing Conflict Minerals for our beverage, food or aerosol containers and the components manufactured by our aerospace division pursuant to the steps in our due diligence program.

In our efforts to determine the mine or location of origin of any Conflict Minerals in our supply chain with the greatest possible specificity, we sent in-scope suppliers the Reporting Template, requesting information pertaining to the source of Conflict Minerals in their materials and/or components, including the source of Conflict Minerals contained in any recycled or scrap materials. Responses were tracked, accompanying information or documentation was reviewed, and additional requests for information were sent, as deemed necessary. Follow-up was performed pursuant to our due diligence program with non-responders and suppliers that provided incomplete responses, based on internally defined criteria, in an effort to obtain more detailed information. Any named smelters in the responses were reviewed against the CFSI Conflict-Free Smelter Program's ("CFSI Program") list of conflict free smelters to confirm conflict-free status.

c. Design and Implement a Strategy to Respond to Risks

As described above, we utilize the Reporting Template to collect information from suppliers and identify risk. When a potential risk is identified, such as nonresponsive suppliers, incomplete Reporting Templates (based on internally defined criteria), or other potential risks, further inquiry takes place. The risk mitigation element of our due diligence program is dependent on the unique circumstances of any issues that may arise. Senior management members of the Conflict Minerals Working Group are advised of any situation where a potential risk is identified. We will also contact any of our suppliers found to be sourcing from the Covered Countries through noncertified smelters, and potentially seek to establish an alternative source for Conflict Minerals.

d. Carryout Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

As part of our due diligence program, we rely on the information provided on the CFSI Program website to determine if the smelters disclosed by our suppliers are certified as conflict free.

e. Report on Supply Chain Due Diligence

Our due diligence program includes filing our Form SD and CMR with the SEC on an annual basis, as well as making our CMR publicly available at
http://www.ball.com/Ball/media/Ball/Global/Downloads/Ball_2016_Conflict_Minerals_Report.pdf, as required by the Rule.

2. Supplier Survey Results

Inherent Limitation on Due Diligence Measures

As a downstream purchaser of materials and components that may contain Conflict Minerals, Ball must necessarily rely, in good faith, on our direct suppliers to provide us with information about the source of Conflict Minerals contained in the materials and/or components supplied to us. We do not have direct relationships with 3TG smelters and refiners and do not perform or direct audits of these entities within our supply chain.

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Results Based on Segment

As noted above, Ball supplies innovative, sustainable packaging solutions for beverage, food and household products customers ("Packaging"), as well as aerospace and other technologies and services primarily for the U.S. government ("Aerospace"). The results of our due diligence for Packaging and Aerospace are reported separately below:

a. Packaging

We received responses from one-hundred percent (100%) of the Packaging segment suppliers surveyed. Forty-five percent (45%) of the Packaging suppliers surveyed indicated in their responses that the Rule was inapplicable to them, or that their products contained no 3TG; thus they were not in-scope. All of the remaining in-scope suppliers indicated that their products or components provided to Ball were Conflict Free because all of their respective smelters were reported as approved smelters under the CFSI Program. However, we are aware that one smelter in our supply chain failed its certification requirements under the CFSI Program for a portion of 2015. It is the Company's understanding, after further engagement with the relevant suppliers and the smelter, that this failure was due to the smelter purchasing a small amount of crude tin from two local smelters that were not on the CFSI approved smelter list. The smelter currently has a corrective action plan in place with the CFSI Program and has been re-certified since December 16, 2015. The Company and the relevant suppliers continue to monitor the smelter's certification under the CFSI Program.

b. Aerospace

We received responses from eighty-four percent (84%) of the Aerospace segment suppliers surveyed. Approximately fifteen percent (15%) of the in-scope Aerospace suppliers surveyed indicated that materials or components they provide to the Company include Conflict Minerals from the Covered Countries; however, these suppliers also indicated that the smelters through which these Conflict Minerals were processed are CFSI Program approved smelters, which we verified to be conflict free against the CFSI Program list of conflict free smelters. Fifty-five percent (55%) of the in-scope Aerospace suppliers surveyed remain undeterminable due to incomplete responses (based on internally defined criteria). Sixteen percent (16%) of the Aerospace suppliers surveyed did not respond to our initial survey request or the additional follow-up we conducted pursuant to our due diligence plan.


3. Description of Products, Facilities Used and Country of Origin of Necessary Conflict Minerals

Ball is a manufacturer of metal packaging products as well as aerospace hardware, which are produced in a network of manufacturing facilities around the world. The tin contained in our metal packaging products is contained in the raw materials provided by our metal suppliers. Our aerospace hardware includes electronic components that contain tantalum, tin, tungsten and gold.


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We have identified twenty (20) smelters for our Packaging segment, and one hundred and forty one (141) smelters for our Aerospace segment, at the product level. This smelter information is provided in Exhibit A. All Packaging smelters listed have been certified as conflict free under the CFSI Program as of the time our due diligence program was performed. Approximately fifteen (15) Aerospace smelters listed were not certified as conflict free under the CFSI Program as of the time our due diligence program was performed. It should be noted that, pursuant to CFSI Program rules and the certification process thereunder, some smelters may not have been compliant for the whole year, some may have failed their re-audit since our due diligence was performed and are in the process of addressing relevant issues, or some smelters may have expired certifications since our due diligence was performed and a re-audit may currently be in process.

4. Steps to be Taken to Mitigate Risk

We intend to take the following steps to improve due diligence conducted regarding Conflict Minerals to further mitigate any risk that the necessary Conflict Minerals in our products could benefit armed groups in the Covered Countries:

a. We will continue to review our due diligence process to ensure all relevant suppliers are sent the Reporting Template, that information is adequately collected and reviewed, appropriate follow-up measures are taken, and that any documentation is centrally collected and maintained.

b. We will continue tracking communication with suppliers to attempt to increase the response rate and improve content and accuracy of the supplier Reporting Template responses.

c. We will attempt to engage any of our suppliers found to be supplying us with 3TG from Covered Countries that support conflict to establish an alternative source of 3TG that does not support such conflict.

d. We will continue to include a Conflict Minerals clause in new supplier contracts.





















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Exhibit A

CFSI Program Processing Facilities as of March 28, 20161

Metal
Processing Facility Name
Country
Segment
Compliant
Gold
Aida Chemical Industries Co., Ltd.
Japan
Aerospace
Yes
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
Germany
Aerospace
Yes
Gold
AngloGold Ashanti Córrego do Sítio Mineração
Brazil
Aerospace
Yes
Gold
Argor-Heraeus SA
Switzerland
Aerospace
Yes
Gold
Asahi Pretec Corporation
Japan
Aerospace
Yes
Gold
Asahi Refining Canada Limited
Canada
Aerospace
Yes
Gold
Asahi Refining USA Inc.
United States
Aerospace
Yes
Gold
Asaka Riken Co., Ltd.
Japan
Aerospace
Yes
Gold
Aurubis AG
Germany
Aerospace
Yes
Gold
C. Hafner GmbH + Co. KG
Germany
Aerospace
Yes
Gold
Caridad
Mexico
Aerospace
No
Gold
CCR Refinery - Glencore Canada Corporation
Canada
Aerospace
Yes
Gold
Chimet S.p.A.
Italy
Aerospace
Yes
Gold
Codelco
Chile
Aerospace
No
Gold
Dowa
Japan
Aerospace
Yes
Gold
Eco-System Recycling Co., Ltd.
Japan
Aerospace
Yes
Gold
Elemetal Refining, LLC
United States
Aerospace
Yes
Gold
Heimerle + Meule GmbH
Germany
Aerospace
Yes
Gold
Heraeus Ltd. Hong Kong
China
Aerospace
Yes
Gold
Heraeus Precious Metals GmbH & Co. KG
Germany
Aerospace
Yes
Gold
Ishifuku Metal Industry Co., Ltd.
Japan
Aerospace
Yes
Gold
Jiangxi Copper Company Limited
China
Aerospace
Yes
Gold
Johnson Matthey Inc.
United States
Aerospace
No
Gold
JX Nippon Mining & Metals Co., Ltd.
Japan
Aerospace
Yes
Gold
Kennecott Utah Copper LLC
United States
Aerospace
Yes
Gold
Kojima Chemicals Co., Ltd.
Japan
Aerospace
Yes
Gold
LS-NIKKO Copper Inc.
Republic of Korea
Aerospace
Yes
Gold
Materion
United States
Aerospace
Yes



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1 Smelters included on this list are those reported at the product level.


Metal
Processing Facility Name
Country
Segment
Compliant
Gold
Matsuda Sangyo Co., Ltd.
Japan
Aerospace
Yes
Gold
Metalor Technologies (Hong Kong) Ltd.
China
Aerospace
Yes
Gold
Metalor Technologies SA
Switzerland
Aerospace
Yes
Gold
Metalor USA Refining Corporation
United States
Aerospace
Yes
Gold
Nihon Material Co., Ltd.
Japan
Aerospace
Yes
Gold
Ohio Precious Metals LLC.
United States
Aerospace
No
Gold
Ohura Precious Metal Industry Co., Ltd.
Japan
Aerospace
Yes
Gold
PAMP SA
Switzerland
Aerospace
Yes
Gold
Rand Refinery (Pty) Ltd.
South Africa
Aerospace
Yes
Gold
Republic Metals Corporation
United States
Aerospace
Yes
Gold
Royal Canadian Mint
Canada
Aerospace
Yes
Gold
Sabin Metal Corp.
United States
Aerospace
No
Gold
SEMPSA Joyería Platería SA
Spain
Aerospace
Yes
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
China
Aerospace
Yes
Gold
Solar Applied Materials Technology Corp.
Taiwan
Aerospace
Yes
Gold
Sumitomo Metal Mining Co., Ltd.
Japan
Aerospace
Yes
Gold
Tanaka Kikinzoku Kogyo K.K.
Japan
Aerospace
Yes
Gold
The Refinery of Shandong Gold Mining Co. Ltd
China
Aerospace
Yes
Gold
Tokuriki Honten Co., Ltd.
Japan
Aerospace
Yes
Gold
Umicore SA Business Unit Precious Metals Refining
Belgium
Aerospace
Yes
Gold
Unicore SA
Belgium
Aerospace
No
Gold
United Precious Metal Refining, Inc.
United States
Aerospace
Yes
Gold
Valcambi SA
Switzerland
Aerospace
Yes
Gold
Western Australian Mint trading as The Perth Mint
Australia
Aerospace
Yes
Gold
Yamamoto Precious Metal Co., Ltd.
Japan
Aerospace
Yes
Gold
Yokohama Metal Co., Ltd.
Japan
Aerospace
Yes
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
China
Aerospace
Yes
Gold
Zijin Mining Group Co., Ltd. Gold Refinery
China
Aerospace
Yes
Gold; Tantalum
Mitsui Mining and Smelting Co., Ltd.
Japan
Aerospace
Yes
Gold; Tin
Mitsubishi Materials Corporation
Japan
Aerospace
Yes



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Metal
Processing Facility Name
Country
Segment
Compliant
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
China
Aerospace
Yes
Tantalum
F&X Electro-Materials Ltd.
China
Aerospace
Yes
Tantalum
Global Advanced Metals Boyertown
United States
Aerospace
Yes
Tantalum
H.C. Starck Co., Ltd.
Thailand
Aerospace
Yes
Tantalum
H.C. Starck Hermsdorf GmbH
Germany
Aerospace
Yes
Tantalum
H.C. Starck Inc.
United States
Aerospace
Yes
Tantalum
H.C. Starck Ltd.
Japan
Aerospace
Yes
Tantalum
Jiujiang Tanbre Co., Ltd.
China
Aerospace
Yes
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
China
Aerospace
Yes
Tantalum
Plansee SE Liezen
Austria
Aerospace
Yes
Tantalum
Solikamsk Magnesium Works OAO
Russian Federation
Aerospace
Yes
Tantalum
Taki Chemicals
Japan
Aerospace
Yes
Tantalum
Ulba Metallurgical Plant JSC
Kazakhstan
Aerospace
Yes
Tantalum
Zhuzhou Cemented Carbide
China
Aerospace
Yes
Tin
Alpha
United States
Aerospace
Yes
Tin
An Vinh Joint Stock Mineral Processing Company
Viet Nam
Aerospace
No
Tin
China Tin Group Co., Ltd.
China
Aerospace
Yes
Tin
CNMC (Guangxi) PGMA Co. Ltd.
China
Aerospace
No
Tin
Cooperativa Metalurgica de Rondônia Ltda.
Brazil
Packaging; Aerospace
Yes
Tin
CV Gita Pesona
Indonesia
Aerospace
Yes
Tin
CV Serumpun Sebalai
Indonesia
Aerospace
Yes
Tin
CV United Smelting
Indonesia
Aerospace
Yes
Tin
EM Vinto
Bolivia
Packaging, Aerospace
Yes
Tin
Fenix Metals
Poland
Aerospace
Yes
Tin
Gejiu Kai Meng Industry and Trade LLC
China
Aerospace
No
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
China
Aerospace
Yes
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
China
Aerospace
No
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
China
Aerospace
Yes
Tin
Magnu's Minerais Metais e Ligas Ltda.
Brazil
Aerospace
Yes
Tin
Malaysia Smelting Corporation
Malaysia
Packaging; Aerospace
Yes
Tin
Melt Metais e Ligas S/A
Brazil
Aerospace
Yes



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Metal
Processing Facility Name
Country
Segment
Compliant
Tin
Metahub
Malaysia
Packaging
Yes
Tin
Metallo-Chimique N.V.
Belgium
Packaging; Aerospace
Yes
Tin
Mineração Taboca S.A.
Brazil
Packaging; Aerospace
Yes
Tin
Minsur
Peru
Packaging; Aerospace
Yes
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
Thailand
Aerospace
Yes
Tin
O.M. Manufacturing Philippines, Inc.
Philippines
Aerospace
Yes
Tin
Operaciones Metalurgical S.A.
Bolivia
Packaging; Aerospace
Yes
Tin
PT Aries Kencana Sejahtera
Indonesia
Packaging; Aerospace
Yes
Tin
PT Artha Cipta Langgeng
Indonesia
Aerospace
Yes
Tin
PT ATD Makmur Mandiri Jaya
Indonesia
Packaging; Aerospace
Yes
Tin
PT Babel Inti Perkasa
Indonesia
Aerospace
Yes
Tin
PT Bangka Putra Karya
Indonesia
Aerospace
No
Tin
PT Bangka Tin Industry
Indonesia
Aerospace
Yes
Tin
PT Belitung Industri Sejahtera
Indonesia
Aerospace
Yes
Tin
PT BilliTin Makmur Lestari
Indonesia
Aerospace
Yes
Tin
PT Bukit Timah
Indonesia
Aerospace
Yes
Tin
PT DS Jaya Abadi
Indonesia
Aerospace
Yes
Tin
PT Eunindo Usaha Mandiri
Indonesia
Aerospace
Yes
Tin
PT Inti Stania Prima
Indonesia
Aerospace
Yes
Tin
PT Justindo
Indonesia
Aerospace
Yes
Tin
PT Mitra Stania Prima
Indonesia
Packaging; Aerospace
Yes
Tin
PT Panca Mega Persada
Indonesia
Aerospace
Yes
Tin
PT Prima Timah Utama
Indonesia
Aerospace
Yes
Tin
PT Refined Bangka Tin
Indonesia
Packaging; Aerospace
Yes
Tin
PT Sariwiguna Binasentosa
Indonesia
Aerospace
Yes
Tin
PT Stanindo Inti Perkasa
Indonesia
Aerospace
Yes
Tin
PT Tambang Timah
Indonesia
Aerospace
No
Tin
PT Timah (Persero) Tbk Kundur
Indonesia
Packaging; Aerospace
Yes



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Metal
Processing Facility Name
Country
Segment
Compliant
Tin
PT Timah (Persero) Tbk Mentok
Indonesia
Packaging; Aerospace
Yes
Tin
PT Tinindo Inter Nusa
Indonesia
Packaging; Aerospace
Yes
Tin
PT Wahana Perkit Jaya
Indonesia
Packaging; Aerospace
Yes
Tin
Rui Da Hung
Taiwan
Packaging; Aerospace
Yes
Tin
Singapore LME Tin
Singapore
Aerospace
No
Tin
Soft Metais Ltda.
Brazil
Aerospace
Yes
Tin
Thaisarco
Thailand
Aerospace
Yes
Tin
White Solder Metalurgia e Mineração Ltda.
Brazil
Packaging; Aerospace
Yes
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
China
Aerospace
No
Tin
Yunnan Chengo Electric Smelting Plant
China
Aerospace
No
Tin
Yunnan Tin Company, Ltd.
China
Packaging; Aerospace
Yes
Tin
Yunnan Tin Group (Holding) Company Limited
China
Packaging; Aerospace
Yes
Tungsten
A.L.M.T. TUNGSTEN Corp.
Japan
Aerospace
Yes
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
China
Aerospace
Yes
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
China
Aerospace
Yes
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
China
Aerospace
Yes
Tungsten
Global Tungsten & Powders Corp.
United States
Aerospace
Yes
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
China
Aerospace
Yes
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
China
Aerospace
Yes
Tungsten
Japan New Metals Co., Ltd.
Japan
Aerospace
Yes
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
China
Aerospace
Yes
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
China
Aerospace
Yes
Tungsten
Kennametal Huntsville
United States
Aerospace
Yes
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
Viet Nam
Aerospace
Yes
Tungsten
Wolfram Bergbau und Hütten AG
Austria
Aerospace
Yes







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