POLICY INFORMATION Ref Number: 4016a Policy Authors - Initials: AMC, LG, LK, MK (revision), DNP (revision), DHP (revision) Title: Inventory Valuation - LIFO Category: Accounting / Reporting Policy Authors - Names: Andy Czyzewski, Linda Green, Linda Kimble, Michelle Kimker (revision), Doug Page (revision), Donna Perry (revision) Additional Review: JSW, KG, ANC (revision), JSW (revision) Final Approval: JSW Orig Approval Date: 2003/05/28 Date Revised: 2011/02/23 Organizational Scope: Geographical Scope: Corporate Global POLICY & PROCEDURE Approved TABLE OF CONTENTS Objective Scope Policy I. General II. SAC US (Co 931) III. COV US (Co 030) IV. Exhibits OBJECTIVE The objective of this policy is to document the accounting procedures in effect at Sealed Air Corporation’s domestic (U.S.) operations relative to the Company’s LIFO inventory valuation method. SCOPE This policy is applicable to SAC US (Co. 931) and COV US (Co. 030) inventory to be valued on a LIFO basis. POLICY I. General • In compliance with current accounting requirements, the Company use the following inventory valuation methods at its domestic operations: • FIFO (first-in, first-out) inventory valuation method is utilized in order to revalue inventory from standard cost to current replacement cost, in conformance with GAAP. (SAC US only). • LIFO (last-in, first-out) inventory is utilized for external reporting and federal tax purposes (SAC US and COV US). • Inventory valuation reserve and related calculations are maintained/prepared separately for SAC US (Co 931) and COV US (Co 030) operations. • • The LIFO (and FIFO, if applicable) reserve adjustment calculations and related journal entries should be prepared and booked on a quarterly basis at a minimum. It is important to maintain consistency in the LIFO accounting practices. As such, any changes to the LIFO accounting practices must be approved by the VP Global Supply Chain Finance and the Corporate Controller. II. SAC US (Co 931) • The inventory valuation calculation is administered by the Supply Chain finance group in Mayhill. • The inventory valuation calculation is prepared and booked on a quarterly basis. • Book value of the inventory at SAC US is maintained at standard cost (for finished goods and work in process) and moving average (for raw materials), with a corresponding FIFO reserve account, which is representative of current cost. • All inventory price and quantity data required for both the FIFO and LIFO calculations are generated from SAP. • The inventory valuation calculation and related workpapers are maintained on Excel spreadsheets. • The dollar-value LIFO method is used for calculating the LIFO reserve adjustment, and the double-extension method for determining the LIFO index. • SAC US currently has two LIFO pools: Food and Packaging. The Food pool includes the Sealed Air Driloc products that are still contained within the SAC US entity. • Except for equipment, parts and solar collector inventory, all inventory is valued on the LIFO basis. Inventory for equipment, parts and solar collectors are carried on the books at standard cost and then revalued to FIFO on a quarterly basis; contingent on significant changes in raw material costs. • Calculation (see attached Exhibits A, B and C): 1. Generate and download LIFO/FIFO reports from SAP. 2. Revalue inventory by “pool” from standard cost to FIFO basis. 3. Record FIFO reserve adjustment. 4. Layer ending LIFO inventory by “pool” using base year cost and current year cost. 5. Calculate the current year LIFO index using the double-extension method. 6. Determine whether a LIFO increment or decrement has occurred for the current year. 7. If a LIFO increment is recognized, value at the current year cost by multiplying the increment by the current year LIFO index, and add to prior year’s ending LIFO balance to arrive at the current year’s ending LIFO inventory. 8. If a LIFO decrement is recognized, it should be deducted from the prior years’ LIFO increments to arrive at the ending LIFO inventory. • Record LIFO reserve adjustment (i.e. difference between ending FIFO and LIFO inventories). The LIFO reserve adjustment is approved by the Director-Supply Chain Finance NA (PP/SM). • • Inventory valuation reserve adjustments and related journal entries are booked by Corporate each quarter in consolidation at the Profit Center level and then pushed down to SAC US (and posted in SAP G/L) at the beginning of each year. LIFO/FIFO reserve adjustments are maintained at the division level and do not impact the monthly financials of the individual plant operations. III. COV US (Co 030) • The LIFO inventory valuation calculation is prepared by the Supply Chain finance group in Duncan. • The LIFO inventory valuation calculation is prepared and reviewed on a monthly basis. As required, entries are booked so that the projected year end reserve will be in place by 12/31. Therefore, depending on the projection for the year end LIFO reserve, entries may or may not be made to book to the monthly calculation. At 12/31 the LIFO reserve is always adjusted to agree to the December LIFO inventory valuation calculation. • Book value of the inventory for COV US is maintained at standard cost for finished goods and work in process and moving average price for raw materials, which is representative of current costs. (Standard costs are reviewed periodically and revised as necessary; contingent on significant changes in raw material costs.) • All inventory price and quantity data required for the LIFO calculation are generated from SAP. • The inventory valuation calculation and related workpapers are maintained in Excel spreadsheets. See Exhibit D for these spreadsheets. • The dollar-value LIFO method is used for calculating the LIFO reserve adjustment and the link-chain method for determining the LIFO index. • COV US currently has one LIFO pool. • All inventories, except for inventory purchased for resale and equipment, are valued on the LIFO basis. Inventory items purchased for resale and equipment are valued at replacement cost (i.e. standard cost). • A detail description of the COV US calculation is attached in Exhibit E. • Cryovac-US LIFO White Paper was written in the mid-1990’s after an IRS audit of Cryovac’s LIFO accounting to document Cryovac’s LIFO accounting methodology and practices. The white paper is included in Exhibit F. An example based on the calculation in the white paper is in Exhibit G. • Journal entry to record necessary LIFO reserve adjustments are manually keyed in to the SAP general ledger. This entry is approved by the Director-Supply Chain Finance NA (COV). • LIFO reserve adjustment is maintained at the division level and does not impact the monthly financials of the individual plant operations. IV. Exhibits [See separate attachments]