Form SD Seneca Foods Corp

---

However, a small portion of the metal food containers that the Company manufactures are sold to other entities.  The Company purchases steel from manufacturers of steel tin plate in order to manufacture metal food containers.  Tin is a conflict mineral that is necessary to the functionality of the metal food container product sold by the Company to other entities.  Therefore, the metal food containers that the Company manufactures for sale to other entities are subject to the reporting obligations of Rule 13p-1 (the "Covered Products").

Reasonable Country of Origin Inquiry

In accordance with the rules, the Company conducted a good faith reasonable country of origin inquiry (RCOI) with respect to the conflict minerals that are necessary for the functionality of the Covered Products manufactured in 2015.  Management members of the Company, consisting of internal audit, container manufacturing, procurement, legal and accounting personnel, among others, worked to identify suppliers of steel and coatings used in the production of the Covered Products.  Memorandums were sent to the Company's direct suppliers of such materials explaining the conflict minerals reporting rule, and requesting information to determine whether raw materials may contain conflict minerals that originated in the Democratic Republic of the Congo or an adjoining country (the "DRC region").  As part of its RCOI the Company's management reviewed responses that the Company received from its suppliers and followed up on inconsistent, incomplete, and inaccurate responses and also called and sent reminders to suppliers who did not initially respond to the Company's requests for information.

Conclusion

Based on the evaluation of the Company's purchased materials, the Company has determined that certain raw materials used by the Company for the manufacture of metal food containers did not contain materials that were subject to the conflict minerals reporting.  For those Covered Products that did contain minerals subject to reporting, based on the RCOI performed with respect to such products, the Company has determined that it has no reason to believe that any conflict mineral necessary for the functionality of the Company's products manufactured in 2015 may have originated in the DRC region.

The Conflict Minerals Disclosure for the calendar year ended December 31, 2015 is available at www.senecafoods.com.  The information contained on the Company's website is not incorporated by reference into this Form SD and should not be considered part of this Form SD.