This policy is primarily for use for U.S. Subsidiaries. Subsidiaries that reside outside of the U.S. should consult with THOR Corporate regarding any policy and procedure questions.
STATEMENT OF POLICY THOR Industries, Inc. (including its operating companies and affiliates, “THOR”, “we”, or “our”) is committed to providing a safe, healthy, and secure world by identifying and reporting Conflict Minerals.The Dodd-Frank Wall Street Reform and ConsumerProtection Act (the "Dodd-Frank Act") was signed into law by President Obama in July 2010. Section1502 of the Dodd-Frank Act imposes certainSecurities and Exchange Commission (“SEC”)reporting requirements on publicly-traded companies whose products contain metals derived from minerals known as "Conflict Minerals", which include gold, tin, tantalum, and tungsten, that originated from the Democratic Republic of Congo ("DRC") or an adjoining country. The reporting requirements reflectCongressional concern that revenues obtained from the mining and transport of Conflict Minerals finance the ongoing conflict in the DRC.
THOR is concerned about the abuses related to the illegal mining and transport of Conflict Minerals in the DRC and intends not only to comply with theseConflict Mineral requirements, but also expects its suppliers to do the same. However, THOR does not purchase any raw materials that are used in the manufacture of its products directly from smelters or mines. Instead, the raw materials pass through several supply chain layers. To determine the source of these raw materials and whether its suppliers' products contain Conflict Minerals from the DRC,Thor conducts due diligence inquiries of its supply chain using a custom Conflict Minerals DisclosureForm that is pre- populated with each supplier’s product information. THOR requests that its suppliers will, as necessary, perform the same due diligence by asking their upstream suppliers about the presence, source, and origin of any ConflictMinerals.
THOR seeks to have its products manufactured with minerals that are conflict free and has devoted significant resources and effort to comply with theConflict Mineral reporting requirements, but the process of tracking the source and origin of ConflictMinerals is a complicated one. Many of THOR’s suppliers may lack the resources to track the ConflictMinerals to the original smelter or mine. THOR will continue to strive to have its suppliers put forth a reasonable effort to track the Conflict Minerals through their supply chains and provide Thor with the information necessary to comply with the ConflictMineral reporting requirements.As this is an ongoing process, Thor will continue to evaluate our policy and methods to ensurecompliance with the SEC’s Conflict Mineral reporting requirements.
REPORTING NON-COMPLIANCE
When in doubt, ask.Whenever you have a question or concern, are unsure about what the appropriate course of action is, or if you suspect that a violation of the law or this Policy has occurred, please talk with your supervisor or the THOR Legal and Compliance Department (Phone: 574-970-7460 or [email protected])or by following the procedures laid out in the Policy and ProceduresGuide SectionADM-0A: Asking for Help andReporting Concerns.