UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
Thor Industries, Inc.
(Exact Name of Registrant as Specified in Charter)
Delaware (State or Other Jurisdiction of Incorporation) |
1-9235 (Commission File Number) |
93-0768752 (IRS Employer Identification No.) |
601 East Beardsley Avenue, Elkhart, Indiana (Address of Principal Executive Offices) |
46514-3305 (Zip Code) |
W. Todd Woelfer Senior Vice President, General Counsel and Corporate Secretary |
(574) 970-7460 |
(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, 2015. |
Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
This Form SD is filed by Thor Industries, Inc. (the “Company”) pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1 through December 31, 2015.
A copy of the Company’s Conflict Minerals Report is filed as Exhibit 1.01 hereto and is incorporated by reference herein. A copy of the report is publicly available at http://ir.thorindustries.com.
Item 1.02 Exhibit
A copy of the Company’s Conflict Minerals Report is filed as Exhibit 1.01 hereto.
Section 2 – Exhibits
Item 2.01 Exhibits
Exhibit Number | Description | |
1.01 | Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form. |
SIGNATURES
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.
Date: May 31, 2016 |
Thor Industries, Inc. | |
By: | /s/ W. Todd Woelfer | |
Name: | W. Todd Woelfer | |
Title: | Senior Vice President, General Counsel and Corporate Secretary |
Exhibit 1.01
I. Introduction
This is the Conflict Minerals1 Report (the “Report”) of Thor Industries, Inc. (“Thor”, the “Company”, “we”, “us”, or “our”) prepared for calendar year 2015 in accordance with Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934 (the “Act”). Numerous terms in this Report are defined in the Rule and Form SD and the reader is referred to those sources and to Release No. 34-67716 (August 22, 2012) of the Act for such definitions.
Thor, through its operating subsidiaries, manufactures a wide range of towable and motorized recreational vehicles that are sold to independent dealers primarily in the United States and Canada. For calendar year 2015, our recreational vehicle operating subsidiaries include Airstream, Inc., Bison Horse Trailers, LLC dba Bison Coach, Cruiser RV, LLC, DRV, LLC, DS Corp. dba CrossRoads RV, Heartland Recreational Vehicles, LLC, KZRV, L.P., Keystone RV Company, Thor Livin’ Lite, Inc. dba Livin’ Lite RV, Inc., and Thor Motor Coach, Inc. Thor is also the sole member of Postle Operating, LLC, a producer of extruded aluminum and specialized components for the recreational vehicle and other industries. As Thor acquired Postle Operating, LLC on May 1, 2015 (the “Acquisition Date”), this Report only includes Postle Operating, LLC’s activities subsequent to the Acquisition Date. For the purpose of this Report, any reference to products manufactured by or suppliers of Thor shall include those products manufactured by and suppliers of Thor’s operating subsidiaries.
Thor’s marketplace is not dominated by publicly traded entities and, as such, is relatively unsophisticated in matters involving rules issued by the Securities and Exchange Commission. This reality of our supply chain offered additional challenges to the implementation of Thor’s Conflict Minerals program.
In accordance with the Rule, Thor undertook efforts to determine whether the necessary Conflict Minerals in our products were sourced from the DRC or a Covered Country. We designed our efforts in conformity with the internationally recognized due diligence framework in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas 2 (“OECD Due Diligence Guidance”) and related Supplements.
Thor’s efforts also utilized multi-industry initiatives with the smelters and refiners of minerals who may provide those minerals to companies in Thor’s supply chain. Thor, as a purchaser of component parts, is many steps removed from the mining of Conflict Minerals; Thor does not purchase raw ore or unrefined Conflict Minerals, and does no purchasing directly in the Covered Countries.
The statements below are based on the due diligence activities performed to date and in good faith by Thor and are based on the infrastructure and information available at the time of this filing. There are factors that could affect the accuracy of these statements, which factors include, but are not limited to, incomplete supplier data or available smelter data, errors or omissions by suppliers or smelters, evolving definition and confirmation of smelters, incomplete information from industry or other third-party sources, continuing guidance regarding the SEC final rules, and other issues.
II. Design of Due Diligence Measures
Thor designed its overall Conflict Minerals program based on the five-step framework of the OECD Due Diligence Guidance, the Supplement on Tin, Tantalum, and Tungsten, and the Supplement on Gold.
Thor’s implementation of the five-step framework consists of the following overarching steps, which are discussed in further detail in Section III.
1 The term “conflict mineral” is defined in Section 1502(e)(4) of the Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo (the “DRC”) or an adjoining country (collectively, the “Conflict Minerals”).
2 OECD (2013), OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition, OECD Publishing. http://www.oecd.org/corporate/mne/GuidanceEdition2.pdf
Step 1: Establish strong company management systems
Step 2: Identify and assess risks in the supply chain
Step 3: Design and implement a strategy to respond to identified risks
Step 4: Carry out independent third-party audit of smelter/refiner's due diligence practices
Step 5: Report annually on supply chain due diligence
III. Due Diligence Measures Performed by Thor
The following describes the measures taken to reasonably determine the country of origin and to exercise due diligence in the mineral supply chain in conformance with the OECD Due Diligence Guidance.
Step 1: Establish strong company management systems
a. | Conflict Minerals Policy – Thor adopted and implemented a Conflict Minerals Policy. It is periodically reviewed and will be updated, if necessary. |
b. | Conflict Minerals Team – We gathered a Conflict Minerals team consisting of Legal, Finance (including Purchasing), and Information Technology members with decision-making authority to manage the data collection, review, and reporting processes and educated internal team members about Conflict Minerals disclosure requirements. |
c. | Supplier Engagement – Thor provided its Conflict Minerals Policy and educational materials to our Vendors (as defined below). Our Vendors were also provided information on the Conflict Minerals disclosure requirements as well as recommendations for developing, implementing, and documenting a Conflict Minerals compliance program. |
d. | Engagement – Thor engaged Conflict Minerals subject matter experts to assist with the due diligence and reporting process. |
e. | Records Management – Thor is maintaining its records relating to its Conflict Minerals program in accordance with the recommended record retention guidelines of five (5) years. |
Step 2: Identify and assess risks in the supply chain
We performed the following steps as part of our risk assessment process:
a. | Identify Products in Scope – We worked closely with our subsidiaries to identify direct vendors and suppliers (our “Vendors”) that provide products potentially containing Conflict Minerals to such subsidiaries. |
b. | Conduct Reasonable Country of Origin Inquiry (“RCOI”) |
i. | Thor contracted with iPoint’s Conflict Minerals Platform (“iPoint”) to automatically collect and manage Conflict Minerals declarations as a way to increase the number and completeness of the Vendors’ responses. |
ii. | We processed the Vendor contact information and products lists provided to Thor by each subsidiary on a monthly or quarterly basis, as applicable, and input such information into iPoint’s database (the “iPoint Database”) for the purpose of tracking the Vendors, the Vendors’ products, our contact efforts with each Vendor, and the Vendors’ responses. |
iii. | We contacted those Vendors for which we did not already have the appropriate contact information by mail to determine an appropriate contact name and e-mail address to which to send our Conflict Mineral requests and added such contact information into the iPoint Database. We followed up with those Vendors multiple times when we failed to receive a response to our request for contact information. |
iv. | Through iPoint, we requested that Vendors (a) create an account with iPoint’s online portal if they had not already done so in previous years and (b) input information concerning the applicable Vendor’s products and the conflict status of the minerals contained in such products. The iPoint online portal is provided free to our Vendors for the Basic platform. For those Vendors that chose not to create an account with iPoint, we requested that such Vendors complete and return a Conflict Minerals Reporting Template (“CMRT”) available from the Conflict-Free Sourcing Initiative (“CFSI”) website. |
v. | We directed our Vendors to pass our request up the supply chain if the Vendor is not the manufacturer of the underlying product. |
vi. | For those Vendors that chose not to create an account with iPoint, we verified the completeness and reasonableness of the returned CMRTs and then uploaded those CMRTs into the iPoint platform for tracking and reporting. |
vii. | For those Vendors that chose to create an account with iPoint, we verified the completeness and reasonableness of their responses through the iPoint platform. |
viii. | In both cases, we followed up with Vendors when we failed to receive a completed or reasonable response. |
ix. | We dedicated a substantial amount of time to answering Vendors’ questions concerning Conflict Minerals, including, but not limited to, questions related to Thor’s reporting requirement, the definition of Conflict Minerals, and the proper completion of the CMRT or iPoint request, as applicable. |
x. | We ran and analyzed reports from iPoint to enable us to track Vendor responses and response rates. |
xi. | While certain Vendors were able to identify the countries of origin of the tin, tantalum, tungsten, and/or gold included in the products that they sell to our subsidiaries, our due diligence efforts did not result in sufficient information to conclusively determine all of the countries of origin of the tin, tantalum, tungsten and/or gold in our products. In an effort to provide as complete of a Report as we can, we have included a list of the countries of origin identified by those Vendors as Appendix I. |
c. | Identify Smelters/Processors – Thor collected a list of smelters/processors that are in its subsidiaries’ supply chains by utilizing the iPoint reporting capabilities and the CFSI’s Conflict-Free Smelter Program. We have provided that list under Section IV (Product Description) below. |
Step 3: Design and implement a strategy to respond to identified risks
As part of the risk mitigation process, the iPoint platform compares the smelters/processors collected from Vendors to the conflict-free smelter lists published by the CFSI.
Step 4: Carry out independent third-party audit of smelter/refiner's due diligence practices
Thor is relying on the iPoint platform and CFSI’s published lists to verify the conflict-free status of smelters/processors that source from Covered Countries.
Step 5: Report annually on supply chain due diligence
Thor’s Conflict Minerals Policy is available to the public on our website, http://ir.thorindustries.com. In addition, Thor’s Conflict Minerals Report has been filed with the SEC and is available on our website, http://ir.thorindustries.com.
IV. Product Description
As noted above, the majority of Thor’s operating subsidiaries manufacture towable and motorized recreational vehicles. Our subsidiaries’ manufacturing processes mainly consist of the assembly of units and utilize products that may include, but are not limited to, electronics, electronic components, chassis, upholstery, flooring products, wood and wood-based products, adhesives, paint, mirrors, glass, plastic, fiberglass, plumbing components, heating and cooling components, furniture, aluminum, steel, extruded polystyrene, appliances, and other similar products. Postle Operating, LLC’s offerings include aluminum extrusions, powder coating and painting services, and specialized component fabrication and utilize products that may include, but are not limited to, aluminum, paint, steel, and other similar products.
Processing Facilities – Based on our due diligence process and the information received from our Vendors, the following facilities were identified by our Vendors as the smelters and refiners of the tin, tantalum, tungsten, and/or gold present in and necessary to the functionality of products manufactured by Thor’s subsidiaries in the year ended December 31, 2015:
Smelter Name | Metal | Country |
Allgemeine Gold-und Silberscheideanstalt A.G. | Gold | GERMANY |
AngloGold Ashanti Córrego do Sítio Mineração | Gold | BRAZIL |
Argor-Heraeus S.A. | Gold | SWITZERLAND |
Asahi Pretec Corp. | Gold | JAPAN |
Asahi Refining USA Inc. | Gold | UNITED STATES |
Asaka Riken Co., Ltd. | Gold | JAPAN |
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Gold | TURKEY |
Aurubis AG | Gold | GERMANY |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Gold | PHILIPPINES |
Boliden AB | Gold | SWEDEN |
C. Hafner GmbH + Co. KG | Gold | GERMANY |
CCR Refinery - Glencore Canada Corporation | Gold | CANADA |
Chimet S.p.A. | Gold | ITALY |
DODUCO GmbH | Gold | GERMANY |
Dowa | Gold | JAPAN |
Eco-System Recycling Co., Ltd. | Gold | JAPAN |
Elemetal Refining, LLC | Gold | UNITED STATES |
Emirates Gold DMCC | Gold | UNITED ARAB EMIRATES |
Heimerle + Meule GmbH | Gold | GERMANY |
Heraeus Ltd. Hong Kong | Gold | CHINA |
Heraeus Precious Metals GmbH & Co. KG | Gold | GERMANY |
Ishifuku Metal Industry Co., Ltd. | Gold | JAPAN |
Istanbul Gold Refinery | Gold | TURKEY |
Japan Mint | Gold | JAPAN |
Jiangxi Copper Co., Ltd. | Gold | CHINA |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Gold | RUSSIAN FEDERATION |
JSC Uralelectromed | Gold | RUSSIAN FEDERATION |
JX Nippon Mining & Metals Co., Ltd. | Gold | JAPAN |
Kazzinc | Gold | KAZAKHSTAN |
Kennecott Utah Copper LLC | Gold | UNITED STATES |
Kojima Chemicals Co., Ltd. | Gold | JAPAN |
LS-NIKKO Copper Inc. | Gold | KOREA, REPUBLIC OF |
Materion | Gold | UNITED STATES |
Matsuda Sangyo Co., Ltd. | Gold | JAPAN |
Metalor Technologies (Hong Kong) Ltd. | Gold | CHINA |
Metalor Technologies (Singapore) Pte., Ltd. | Gold | SINGAPORE |
Metalor Technologies S.A. | Gold | SWITZERLAND |
Metalor USA Refining Corporation | Gold | UNITED STATES |
METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | Gold | MEXICO |
Mitsubishi Materials Corporation | Gold | JAPAN |
Mitsui Mining and Smelting Co., Ltd. | Gold | JAPAN |
MMTC-PAMP India Pvt., Ltd. | Gold | INDIA |
Moscow Special Alloys Processing Plant | Gold | RUSSIAN FEDERATION |
Nadir Metal Rafineri San. Ve Tic. A.Ş. | Gold | TURKEY |
Nihon Material Co., Ltd. | Gold | JAPAN |
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | Gold | AUSTRIA |
Ohura Precious Metal Industry Co., Ltd. | Gold | JAPAN |
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Gold | RUSSIAN FEDERATION |
OJSC Novosibirsk Refinery | Gold | RUSSIAN FEDERATION |
PAMP S.A. | Gold | SWITZERLAND |
Prioksky Plant of Non-Ferrous Metals | Gold | RUSSIAN FEDERATION |
PT Aneka Tambang (Persero) Tbk | Gold | INDONESIA |
PX Précinox S.A. | Gold | SWITZERLAND |
Rand Refinery (Pty) Ltd. | Gold | SOUTH AFRICA |
Republic Metals Corporation | Gold | UNITED STATES |
Royal Canadian Mint | Gold | CANADA |
Schone Edelmetaal B.V. | Gold | NETHERLANDS |
SEMPSA Joyería Platería S.A. | Gold | SPAIN |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | Gold | CHINA |
Sichuan Tianze Precious Metals Co., Ltd. | Gold | CHINA |
Singway Technology Co., Ltd. | Gold | TAIWAN |
SOE Shyolkovsky Factory of Secondary Precious Metals | Gold | RUSSIAN FEDERATION |
Solar Applied Materials Technology Corp. | Gold | TAIWAN |
Sumitomo Metal Mining Co., Ltd. | Gold | JAPAN |
T.C.A S.p.A | Gold | ITALY |
Tanaka Kikinzoku Kogyo K.K. | Gold | JAPAN |
The Refinery of Shandong Gold Mining Co., Ltd. | Gold | CHINA |
Tokuriki Honten Co., Ltd. | Gold | JAPAN |
Umicore Brasil Ltda. | Gold | BRAZIL |
Umicore Precious Metals Thailand | Gold | THAILAND |
Umicore S.A. Business Unit Precious Metals Refining | Gold | BELGIUM |
United Precious Metal Refining, Inc. | Gold | UNITED STATES |
Valcambi S.A. | Gold | SWITZERLAND |
Western Australian Mint trading as The Perth Mint | Gold | AUSTRALIA |
Yamamoto Precious Metal Co., Ltd. | Gold | JAPAN |
Yokohama Metal Co., Ltd. | Gold | JAPAN |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation | Gold | CHINA |
Zijin Mining Group Co., Ltd. Gold Refinery | Gold | CHINA |
Changsha South Tantalum Niobium Co., Ltd. | Tantalum | CHINA |
Conghua Tantalum and Niobium Smeltry | Tantalum | CHINA |
D Block Metals, LLC | Tantalum | UNITED STATES |
Duoluoshan | Tantalum | CHINA |
Exotech Inc. | Tantalum | UNITED STATES |
F&X Electro-Materials Ltd. | Tantalum | CHINA |
FIR Metals & Resource Ltd. | Tantalum | CHINA |
Global Advanced Metals Aizu | Tantalum | JAPAN |
Global Advanced Metals Boyertown | Tantalum | UNITED STATES |
Guangdong Zhiyuan New Material Co., Ltd. | Tantalum | CHINA |
H.C. Starck Co., Ltd. | Tantalum | THAILAND |
H.C. Starck GmbH Goslar | Tantalum | GERMANY |
H.C. Starck GmbH Laufenburg | Tantalum | GERMANY |
H.C. Starck Hermsdorf GmbH | Tantalum | GERMANY |
H.C. Starck Inc. | Tantalum | UNITED STATES |
H.C. Starck Ltd. | Tantalum | JAPAN |
H.C. Starck Smelting GmbH & Co. KG | Tantalum | GERMANY |
Hengyang King Xing Lifeng New Materials Co., Ltd. | Tantalum | CHINA |
Hi-Temp Specialty Metals, Inc. | Tantalum | UNITED STATES |
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | Tantalum | CHINA |
Jiangxi Tuohong New Raw Material | Tantalum | CHINA |
JiuJiang JinXin Nonferrous Metals Co., Ltd. | Tantalum | CHINA |
Jiujiang Tanbre Co., Ltd. | Tantalum | CHINA |
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | Tantalum | CHINA |
KEMET Blue Metals | Tantalum | MEXICO |
KEMET Blue Powder | Tantalum | UNITED STATES |
King-Tan Tantalum Industry Ltd. | Tantalum | CHINA |
LSM Brasil S.A. | Tantalum | BRAZIL |
Metallurgical Products India Pvt., Ltd. | Tantalum | INDIA |
Mineração Taboca S.A. | Tantalum | BRAZIL |
Mitsui Mining & Smelting | Tantalum | JAPAN |
Molycorp Silmet A.S. | Tantalum | ESTONIA |
Ningxia Orient Tantalum Industry Co., Ltd. | Tantalum | CHINA |
Plansee SE Liezen | Tantalum | AUSTRIA |
Plansee SE Reutte | Tantalum | AUSTRIA |
QuantumClean | Tantalum | UNITED STATES |
Resind Indústria e Comércio Ltda. | Tantalum | BRAZIL |
RFH Tantalum Smeltry Co., Ltd. | Tantalum | CHINA |
Solikamsk Magnesium Works OAO | Tantalum | RUSSIAN FEDERATION |
Taki Chemicals | Tantalum | JAPAN |
Telex Metals | Tantalum | UNITED STATES |
Tranzact, Inc. | Tantalum | UNITED STATES |
Ulba Metallurgical Plant JSC | Tantalum | KAZAKHSTAN |
XinXing HaoRong Electronic Material Co., Ltd. | Tantalum | CHINA |
Yichun Jin Yang Rare Metal Co., Ltd. | Tantalum | CHINA |
Zhuzhou Cemented Carbide | Tantalum | CHINA |
Alpha | Tin | UNITED STATES |
China Tin Group Co., Ltd. | Tin | CHINA |
Cooperativa Metalurgica de Rondônia Ltda. | Tin | BRAZIL |
CV Ayi Jaya | Tin | INDONESIA |
CV Gita Pesona | Tin | INDONESIA |
CV Serumpun Sebalai | Tin | INDONESIA |
CV United Smelting | Tin | INDONESIA |
CV Venus Inti Perkasa | Tin | INDONESIA |
Dowa | Tin | JAPAN |
Elmet S.L.U. (Metallo Group) | Tin | SPAIN |
EM Vinto | Tin | BOLIVIA |
Fenix Metals | Tin | POLAND |
Gejiu Non-Ferrous Metal Processing Co., Ltd. | Tin | CHINA |
Jiangxi Ketai Advanced Material Co., Ltd. | Tin | CHINA |
Magnu's Minerais Metais e Ligas Ltda. | Tin | BRAZIL |
Malaysia Smelting Corporation (MSC) | Tin | MALAYSIA |
Melt Metais e Ligas S.A. | Tin | BRAZIL |
Metallic Resources, Inc. | Tin | UNITED STATES |
Metallo-Chimique N.V. | Tin | BELGIUM |
Mineração Taboca S.A. | Tin | BRAZIL |
Minsur | Tin | PERU |
Mitsubishi Materials Corporation | Tin | JAPAN |
O.M. Manufacturing (Thailand) Co., Ltd. | Tin | THAILAND |
O.M. Manufacturing Philippines, Inc. | Tin | PHILIPPINES |
Operaciones Metalurgical S.A. | Tin | BOLIVIA |
PT Aries Kencana Sejahtera | Tin | INDONESIA |
PT Artha Cipta Langgeng | Tin | INDONESIA |
PT ATD Makmur Mandiri Jaya | Tin | INDONESIA |
PT Babel Inti Perkasa | Tin | INDONESIA |
PT Bangka Prima Tin | Tin | INDONESIA |
PT Bangka Tin Industry | Tin | INDONESIA |
PT Belitung Industri Sejahtera | Tin | INDONESIA |
PT BilliTin Makmur Lestari | Tin | INDONESIA |
PT Bukit Timah | Tin | INDONESIA |
PT Cipta Persada Mulia | Tin | INDONESIA |
PT DS Jaya Abadi | Tin | INDONESIA |
PT Eunindo Usaha Mandiri | Tin | INDONESIA |
PT Inti Stania Prima | Tin | INDONESIA |
PT Justindo | Tin | INDONESIA |
PT Mitra Stania Prima | Tin | INDONESIA |
PT Panca Mega Persada | Tin | INDONESIA |
PT Prima Timah Utama | Tin | INDONESIA |
PT Refined Bangka Tin | Tin | INDONESIA |
PT Sariwiguna Binasentosa | Tin | INDONESIA |
PT Stanindo Inti Perkasa | Tin | INDONESIA |
PT Sumber Jaya Indah | Tin | INDONESIA |
PT Timah (Persero) Tbk Kundur | Tin | INDONESIA |
PT Timah (Persero) Tbk Mentok | Tin | INDONESIA |
PT Tinindo Inter Nusa | Tin | INDONESIA |
PT Tommy Utama | Tin | INDONESIA |
PT Wahana Perkit Jaya | Tin | INDONESIA |
Resind Indústria e Comércio Ltda. | Tin | BRAZIL |
Rui Da Hung | Tin | TAIWAN |
Soft Metais Ltda. | Tin | BRAZIL |
Thaisarco | Tin | THAILAND |
VQB Mineral and Trading Group JSC | Tin | VIET NAM |
White Solder Metalurgia e Mineração Ltda. | Tin | BRAZIL |
Yunnan Tin Group (Holding) Company Limited | Tin | CHINA |
PT Sukses Inti Makmur | Tin | INDONESIA |
A.L.M.T. TUNGSTEN Corp. | Tungsten | JAPAN |
Asia Tungsten Products Vietnam Ltd. | Tungsten | VIET NAM |
Chenzhou Diamond Tungsten Products Co., Ltd. | Tungsten | CHINA |
Chongyi Zhangyuan Tungsten Co., Ltd. | Tungsten | CHINA |
Fujian Jinxin Tungsten Co., Ltd. | Tungsten | CHINA |
Ganzhou Huaxing Tungsten Products Co., Ltd. | Tungsten | CHINA |
Ganzhou Jiangwu Ferrotungsten Co., Ltd. | Tungsten | CHINA |
Ganzhou Seadragon W & Mo Co., Ltd. | Tungsten | CHINA |
Ganzhou Yatai Tungsten Co., Ltd. | Tungsten | CHINA |
Global Tungsten & Powders Corp. | Tungsten | UNITED STATES |
Guangdong Xianglu Tungsten Co., Ltd. | Tungsten | CHINA |
H.C. Starck GmbH | Tungsten | GERMANY |
H.C. Starck Smelting GmbH & Co.KG | Tungsten | GERMANY |
Hunan Chenzhou Mining Co., Ltd. | Tungsten | CHINA |
Hunan Chunchang Nonferrous Metals Co., Ltd. | Tungsten | CHINA |
Hydrometallurg, JSC | Tungsten | RUSSIAN FEDERATION |
Japan New Metals Co., Ltd. | Tungsten | JAPAN |
Jiangxi Gan Bei Tungsten Co., Ltd. | Tungsten | CHINA |
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | Tungsten | CHINA |
Kennametal Huntsville | Tungsten | UNITED STATES |
Malipo Haiyu Tungsten Co., Ltd. | Tungsten | CHINA |
Niagara Refining LLC | Tungsten | UNITED STATES |
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | Tungsten | VIET NAM |
Tejing (Vietnam) Tungsten Co., Ltd. | Tungsten | VIET NAM |
Vietnam Youngsun Tungsten Industry Co., Ltd. | Tungsten | VIET NAM |
Wolfram Bergbau und Hütten AG | Tungsten | AUSTRIA |
Xiamen Tungsten Co., Ltd. | Tungsten | CHINA |
Xinhai Rendan Shaoguan Tungsten Co., Ltd. | Tungsten | CHINA |
V. Steps to Improve Due Diligence
We will continue to communicate our expectations and information requirements to our Vendors. We will also continue to monitor changes in circumstances that may impact the facts or our determination. Over time, we anticipate that the amount of information available globally on the traceability and sourcing of these ores will increase and improve our knowledge. We will continue to make inquiries to our Vendors and undertake additional risk assessments when potentially relevant changes in facts or circumstances are identified. If we become aware of a Vendor that needs improvement in its due diligence process, we intend to continue the trade relationship while that Vendor improves its compliance program. We expect our Vendors to take similar measures with their suppliers to ensure alignment throughout the supply chain.
In addition to those above, the Company will undertake the following steps during the next compliance period to improve the due diligence conducted and to further mitigate the risk that the necessary Conflict Minerals do not benefit armed groups, including:
· | Review and enhance the reporting platform as necessary to improve Vendors’ ability to accurately and completely respond. |
· | Seek improvement in our own internal vendor identification to allow for increased proficiency in the inquiry and reporting process. |
· | Consider the implementation of all feasible recommendations issued through an outside consultant with experience and expertise related to the Conflict Minerals rules and requirements. |
· | Continue to create an internal database of products known to or believed to contain minerals that are possibly from conflict smelters to allow for further diligence on the suppliers of such products, if necessary. |
VI. Independent Private Sector Audit
Not required for calendar year 2015.
APPENDIX I
Countries of Origin
The information provided in this Appendix is based on the information collected from Thor’s subsidiaries’ Vendors.
Argentina | Indonesia | Rwanda |
Australia | Italy | Sierre Leone |
Austria | Japan | Singapore |
Belarus | Kazakhstan | South Africa |
Belgium | Kyrgyzstan | South Korea |
Bolivia | Laos | Spain |
Brazil | Malaysia | Suriname |
Burundi | Mexico | Sweden |
Canada | Mongolia | Switzerland |
Chile | Morocco | Taiwan |
China | Mozambique | Tajikistan |
Democratic Republic of the Congo | Myanmar | Thailand |
England | Namibia | Turkey |
Estonia | Niger | United Kingdom |
Ethiopia | Nigeria | United States of America |
France | Peru | Uzbekistan |
Germany | Philippines | Vietnam |
Guinea | Poland | Zambia |
Guyana | Portugal | Zimbabwe |
India | Russia |