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:
R | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2016. |
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, 2016.
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 30, 2017 | Thor Industries, Inc. | |
By: | /s/ W. Todd Woelfer | |
Name: | W. Todd Woelfer | |
Title: | Senior Vice President, General Counsel and Corporate Secretary |
Exhibit 1.01
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
CONFLICT MINERALS REPORT OF
THOR INDUSTRIES, INC.
IN ACCORDANCE WITH RULE 13p-1
UNDER THE SECURITIES EXCHANGE ACT OF 1934
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.)
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 2016 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 2016, 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, Jayco, Inc., 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 Jayco, Inc. on June 30, 2016 (the “Acquisition Date”), this Report only includes Jayco, Inc.’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 CFSI-compliant 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, 2016:
Smelter Name | Metal | Country |
Advanced Chemical Company | Gold | USA |
Aida Chemical Industries Co., Ltd. | Gold | JAPAN |
Allgemeine Gold-und Silberscheideanstalt A.G. | Gold | GERMANY |
Almalyk Mining and Metallurgical Complex (AMMC) | Gold | UZBEKISTAN |
AngloGold Ashanti Córrego do Sítio Mineração | Gold | BRAZIL |
Argor-Heraeus S.A. | Gold | SWITZERLAND |
Asahi Pretec Corp. | Gold | JAPAN |
Asahi Refining Canada Ltd. | Gold | CANADA |
Asahi Refining USA Inc. | Gold | USA |
Asaka Riken Co., Ltd. | Gold | JAPAN |
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 |
DSC (Do Sung Corporation) | Gold | KOREA, REPUBLIC OF |
Daejin Indus Co., Ltd. | Gold | KOREA, REPUBLIC OF |
Eco-System Recycling Co., Ltd. | Gold | JAPAN |
Elemetal Refining, LLC | Gold | USA |
Heimerle + Meule GmbH | Gold | GERMANY |
Heraeus Metals Hong Kong Ltd. | Gold | CHINA |
Heraeus Precious Metals GmbH & Co. KG | Gold | GERMANY |
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | Gold | CHINA |
Ishifuku Metal Industry Co., Ltd. | Gold | JAPAN |
Istanbul Gold Refinery | Gold | TURKEY |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Gold | RUSSIAN FEDERATION |
JSC Uralelectromed | Gold | RUSSIAN FEDERATION |
JX Nippon Mining & Metals Co., Ltd. | Gold | JAPAN |
Japan Mint | Gold | JAPAN |
Jiangxi Copper Co., Ltd. | Gold | CHINA |
Kazzinc | Gold | KAZAKHSTAN |
Kennecott Utah Copper LLC | Gold | USA |
Kojima Chemicals Co., Ltd. | Gold | JAPAN |
Kyrgyzaltyn JSC | Gold | KYRGYZSTAN |
LS-NIKKO Copper Inc. | Gold | KOREA, REPUBLIC OF |
Materion | Gold | USA |
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 | USA |
Metalúrgica Met-Mex Peñoles S.A. De C.V. | Gold | Mexico |
Mitsubishi Materials Corporation | Gold | JAPAN |
Mitsui Mining and Smelting Co., Ltd. | Gold | JAPAN |
Moscow Special Alloys Processing Plant | Gold | RUSSIAN FEDERATION |
Nadir Metal Rafineri San. Ve Tic. A.Ş. | Gold | TURKEY |
Nihon Material Co., Ltd. | Gold | JAPAN |
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Gold | RUSSIAN FEDERATION |
OJSC Novosibirsk Refinery | Gold | RUSSIAN FEDERATION |
Ohura Precious Metal Industry Co., Ltd. | Gold | JAPAN |
PAMP S.A. | Gold | SWITZERLAND |
PT Aneka Tambang (Persero) Tbk | Gold | INDONESIA |
PX Précinox S.A. | Gold | SWITZERLAND |
Prioksky Plant of Non-Ferrous Metals | Gold | RUSSIAN FEDERATION |
Rand Refinery (Pty) Ltd. | Gold | SOUTH AFRICA |
Republic Metals Corporation | Gold | USA |
Royal Canadian Mint | Gold | CANADA |
SEMPSA Joyería Platería S.A. | Gold | SPAIN |
SOE Shyolkovsky Factory of Secondary Precious Metals | Gold | RUSSIAN FEDERATION |
Samduck Precious Metals | Gold | KOREA, REPUBLIC OF |
Schone Edelmetaal B.V. | Gold | NETHERLANDS |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | Gold | CHINA |
Sichuan Tianze Precious Metals Co., Ltd. | Gold | CHINA |
Solar Applied Materials Technology Corp. | Gold | TAIWAN |
Sumitomo Metal Mining Co., Ltd. | Gold | JAPAN |
Tanaka Kikinzoku Kogyo K.K. | Gold | JAPAN |
The Refinery of Shandong Gold Mining Co., Ltd. | Gold | CHINA |
Tokuriki Honten Co., Ltd. | Gold | JAPAN |
Torecom | Gold | KOREA, REPUBLIC OF |
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 | USA |
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 |
AU Traders and Refiners | Gold | SOUTH AFRICA |
Al Etihad Gold LLC | Gold | USA |
Dowa | Gold | JAPAN |
Emirates Gold DMCC | Gold | UNITED ARAB EMIRATES |
Korea Zinc Co., Ltd. | Gold | KOREA, REPUBLIC OF |
MMTC-PAMP India Pvt., Ltd. | Gold | INDIA |
Metalor Technologies (Suzhou) Ltd. | Gold | CHINA |
SAXONIA Edelmetalle GmbH | Gold | GERMANY |
Singway Technology Co., Ltd. | Gold | TAIWAN |
T.C.A S.p.A | Gold | ITALY |
WIELAND Edelmetalle GmbH | Gold | GERMANY |
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | Gold | AUSTRIA |
Changsha South Tantalum Niobium Co., Ltd. | Tantalum | CHINA |
Conghua Tantalum and Niobium Smeltry | Tantalum | CHINA |
D Block Metals, LLC | Tantalum | USA |
Duoluoshan | Tantalum | CHINA |
Exotech Inc. | Tantalum | USA |
F&X Electro-Materials Ltd. | Tantalum | CHINA |
FIR Metals & Resource Ltd. | Tantalum | CHINA |
Global Advanced Metals Aizu | Tantalum | JAPAN |
Global Advanced Metals Boyertown | Tantalum | USA |
Guangdong Zhiyuan New Material Co., Ltd. | Tantalum | CHINA |
H.C. Starck Co., Ltd. | Tantalum | THAILAND |
H.C. Starck Hermsdorf GmbH | Tantalum | GERMANY |
H.C. Starck Inc. | Tantalum | USA |
H.C. Starck Ltd. | Tantalum | JAPAN |
H.C. Starck Smelting GmbH & Co. KG | Tantalum | GERMANY |
H.C. Starck Tantalum and Niobium GmbH | Tantalum | GERMANY |
Hengyang King Xing Lifeng New Materials Co., Ltd. | Tantalum | CHINA |
Hi-Temp Specialty Metals, Inc. | Tantalum | USA |
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | Tantalum | CHINA |
Jiangxi Tuohong New Raw Material | Tantalum | CHINA |
JiuJiang JinXin Nonferrous Metals Co., Ltd. | Tantalum | CHINA |
Jiujiang Nonferrous Metals Smelting Company Limited | Tantalum | CHINA |
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | Tantalum | CHINA |
KEMET Blue Metals | Tantalum | MEXICO |
KEMET Blue Powder | Tantalum | USA |
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 and Smelting Co., Ltd. | Tantalum | JAPAN |
Molycorp Silmet A.S. | Tantalum | ESTONIA |
Ningxia Orient Tantalum Industry Co., Ltd. | Tantalum | CHINA |
Power Resources Ltd. | Tantalum | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF |
QuantumClean | Tantalum | USA |
Resind Indústria e Comércio Ltda. | Tantalum | BRAZIL |
Solikamsk Magnesium Works OAO | Tantalum | RUSSIAN FEDERATION |
Taki Chemical Co., Ltd. | Tantalum | JAPAN |
Telex Metals | Tantalum | USA |
Tranzact, Inc. | Tantalum | USA |
Ulba Metallurgical Plant JSC | Tantalum | KAZAKHSTAN |
XinXing HaoRong Electronic Material Co., Ltd. | Tantalum | CHINA |
Yanling Jincheng Tantalum Co., Ltd. | Tantalum | CHINA |
Yichun Jin Yang Rare Metal Co., Ltd. | Tantalum | CHINA |
Zhuzhou Cemented Carbide Group Co., Ltd. | Tantalum | CHINA |
Alpha | Tin | USA |
CV Gita Pesona | Tin | INDONESIA |
CV Serumpun Sebalai | Tin | INDONESIA |
CV United Smelting | Tin | INDONESIA |
CV Venus Inti Perkasa | Tin | INDONESIA |
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | Tin | CHINA |
China Tin Group Co., Ltd. | Tin | CHINA |
Cooperativa Metalurgica de Rondônia Ltda. | Tin | BRAZIL |
Dowa | Tin | JAPAN |
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 |
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 Babel Inti Perkasa | Tin | INDONESIA |
PT Bangka Tin Industry | Tin | INDONESIA |
PT Belitung Industri Sejahtera | Tin | INDONESIA |
PT Bukit Timah | Tin | INDONESIA |
PT DS Jaya Abadi | Tin | INDONESIA |
PT Eunindo Usaha Mandiri | Tin | INDONESIA |
PT Inti Stania Prima | Tin | INDONESIA |
PT Karimun Mining | 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 |
Rui Da Hung | Tin | TAIWAN |
Soft Metais Ltda. | Tin | BRAZIL |
Thaisarco | Tin | THAILAND |
White Solder Metalurgia e Mineração Ltda. | Tin | BRAZIL |
Yunnan Tin Company Limited | Tin | CHINA |
Gejiu Jinye Mineral Company | Tin | CHINA |
CV Ayi Jaya | Tin | INDONESIA |
CV Dua Sekawan | Tin | INDONESIA |
CV Tiga Sekawan | Tin | INDONESIA |
Elmet S.L.U. | Tin | SPAIN |
Gejiu Fengming Metallurgy Chemical Plant | Tin | CHINA |
Guanyang Guida Nonferrous Metal Smelting Plant | Tin | CHINA |
HuiChang Hill Tin Industry Co., Ltd. | Tin | CHINA |
Metallic Resources, Inc. | Tin | USA |
PT ATD Makmur Mandiri Jaya | Tin | INDONESIA |
PT Bangka Prima Tin | Tin | INDONESIA |
PT Cipta Persada Mulia | Tin | INDONESIA |
PT Kijang Jaya Mandiri | Tin | INDONESIA |
PT Lautan Harmonis Sejahtera | Tin | INDONESIA |
PT Menara Cipta Mulia | Tin | INDONESIA |
PT O.M. Indonesia | Tin | INDONESIA |
PT Sukses Inti Makmur | Tin | INDONESIA |
PT Wahana Perkit Jaya | Tin | INDONESIA |
Resind Indústria e Comércio Ltda. | Tin | BRAZIL |
VQB Mineral and Trading Group JSC | Tin | VIET NAM |
Ganzhou Seadragon W & Mo Co., Ltd. | Tungsten | CHINA |
Guangdong Xianglu Tungsten Co., Ltd. | Tungsten | CHINA |
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 |
Global Tungsten & Powders Corp. | Tungsten | USA |
H.C. Starck Smelting GmbH & Co. KG | Tungsten | GERMANY |
H.C. Starck Tungsten GmbH | Tungsten | GERMANY |
Hunan Chenzhou Mining Co., Ltd. | Tungsten | CHINA |
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | Tungsten | CHINA |
Hunan Chunchang Nonferrous Metals Co., Ltd. | Tungsten | CHINA |
Hydrometallurg, JSC | Tungsten | RUSSIAN FEDERATION |
Japan New Metals Co., Ltd. | Tungsten | JAPAN |
Jiangwu H.C. Starck Tungsten Products Co., Ltd. | Tungsten | CHINA |
Jiangxi Gan Bei Tungsten Co., Ltd. | Tungsten | CHINA |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | Tungsten | CHINA |
Jiangxi Xinsheng Tungsten Industry Co., Ltd. | Tungsten | CHINA |
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | Tungsten | CHINA |
Jiangxi Yaosheng Tungsten Co., Ltd. | Tungsten | CHINA |
Kennametal Fallon | Tungsten | USA |
Kennametal Huntsville | Tungsten | USA |
Malipo Haiyu Tungsten Co., Ltd. | Tungsten | CHINA |
Moliren Ltd | Tungsten | RUSSIAN FEDERATION |
Niagara Refining LLC | Tungsten | USA |
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | Tungsten | VIET NAM |
Philippine Chuangxin Industrial Co., Inc. | Tungsten | PHILIPPINES |
South-East Nonferrous Metal Company Limited of Hengyang City | Tungsten | CHINA |
Tejing (Vietnam) Tungsten Co., Ltd. | Tungsten | VIET NAM |
Unecha Refractory metals plant | Tungsten | RUSSIAN FEDERATION |
Vietnam Youngsun Tungsten Industry Co., Ltd. | Tungsten | VIET NAM |
Wolfram Bergbau und Hütten AG | Tungsten | AUSTRIA |
Woltech Korea Co., Ltd. | Tungsten | KOREA, REPUBLIC OF |
Xiamen Tungsten (H.C.) Co., Ltd. | Tungsten | CHINA |
Xiamen Tungsten Co., Ltd. | Tungsten | CHINA |
Xinfeng Huarui Tungsten & Molybdenum New Material 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 2016.
APPENDIX I
Countries of Origin
The information provided in this Appendix is based on the information collected from Thor’s subsidiaries’ Vendors.
Angola | Guinea | Philippines |
Argentina | Guyana | Poland |
Armenia | Hong Kong | Portugal |
Australia | Hungary | Russia |
Austria | India | Rwanda |
Azerbaijan | Indonesia | Saudi Arabia |
Bangka | Ireland | Sierra Leone |
Belarus | Israel | Singapore |
Belgium | Italy | Slovakia |
Bermuda | Japan | South Africa |
Boliva | Jersey | South America |
Brazil | Kazakhstan | South East Asia |
Burkina Faso | Kenya | South Korea |
Burundi | Kyrgyzstan | South Sudan |
Cambodia | Laos | Spain |
Canada | Liberia | Suriname |
Central African Republic | Luxembourg | Sweden |
Chile | Madagascar | Switzerland |
China | Malaysia | Taiwan |
Columbia | Mali | Tajikistan |
Czech Republic | Mauritania | Tanzania |
Democratic Republic of Congo | Merrimak | Thailand |
Djibouti | Mexico | Turkey |
Domincan Republic | Mongolia | Uganda |
Ecuador | Mozambique | United Arab Emirates |
Egypt | Myanmar | United Kingdom |
Estonia | Namibia | United States |
Ethiopia | Netherlands | Uzbekistan |
Finland | Niger | Vietnam |
France | Nigeria | Zambia |
Germany | Papua New Guinea | Zimbabwe |
Ghana | Peru |
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 30, 2017 | Thor Industries, Inc. | |
By: | /s/ W. Todd Woelfer | |
Name: | W. Todd Woelfer | |
Title: | Senior Vice President, General Counsel and Corporate Secretary |