Exhibit 1.02 Conflict Minerals Report
| I. | Introduction |
The Covered Products produced by Arctic Cat are sport and recreational off-highway vehicles, such as snowmobiles and all-terrain vehicles, as well as related parts, lubricants, garments and accessories. While many of our products incorporate parts and assemblies fabricated from metals, we do not source 3TG directly from mines or from smelters or refiners. However, our Covered Products incorporate a variety of materials, subassemblies and other items that we acquire from a large number of unaffiliated suppliers and that we have reason to believe may contain 3TG.
| II. | Reasonable Country of Origin Inquiry (RCOI) |
We surveyed our largest direct suppliers of materials and components identified as possibly containing 3TG regarding the country of origin of 3TG used in materials, subassemblies or other items supplied by them to Arctic Cat. Direct suppliers were asked to provide answers to the Electronic Industry Citizenship Coalition-Global e-Sustainability Initiative (EICC-GeSI) Conflict Minerals Common Reporting Template reflecting our position on the supply chain. The EICC-GeSI Conflict Minerals Common Reporting Template is regarded as the most common reporting tool for conflict minerals content and sourcing information worldwide, developed by several of the world’s leading consumer electronics companies. At the time of this report, we have received responses from over 70% of the direct suppliers surveyed. We reviewed the responses received from suppliers for completeness and consistency and, in certain cases suppliers were required to provide corrections and clarifications to their initial responses. As such, we believe our RCOI process was reasonably designed and performed in good faith.
| III. | Due Diligence |
We performed due diligence in conformity with nationally and internationally recognized due diligence frameworks. Specifically, we designed and implemented our overall conflict minerals due diligence based on, and in conformity with the five step framework of OECD (2011),OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the supplements on tin, tantalum, tungsten and gold. We implemented appropriate elements of Steps 1, 2 and 5 of the Guidance, although those relate to SEC regulatory steps that precede and follow the specific due diligence boundaries. Therefore, the design of our due diligence process conforms to Steps 3 and 4 of the OECD Guidance as applicable to our circumstances and position in the supply chain as a “downstream” company with little to no direct influence on smelters/refiners. Further, using the EICC/GeSI Conflict Minerals Common Reporting Template, direct suppliers were asked to provide answers regarding the facilities used to process the 3TG and the status of such facilities as “conflict free” pursuant to the nationally and internationally-recognized Conflict Free Smelter Program (http://www.conflictfreesourcing.org/conflict-free-smelter-program/).
In addition to these efforts, we have performed and/or will continue to perform the following due diligence measures:
| • | Reporting to senior management on direct suppliers’ responses to our conflict minerals information requests, including updates on monitoring and tracking corrective action and risk mitigation efforts (where applicable); |
| • | Developing and communicating our policy on Conflict Minerals to direct suppliers; |
| • | Providing awareness concerning the commitments and requirements expected of our suppliers with respect to Conflict Minerals in the supply chain, supported by email and phone dialogues; |
| • | Encouraging suppliers to develop policies on Conflict Minerals and to mitigate risk of inclusion of Conflict Minerals in the supply chain; |
| • | Developing a risk mitigation plan that allows for continued trade with a supplier during the supplier’s risk mitigation efforts; |
| • | Supporting the development and implementation of independent third party audits of smelter/refiner’s sourcing through our policy and procurement practices that encourage suppliers to purchase materials from audited smelters/refiners. |
No independent private sector audit is required for calendar year 2013.
| IV. | Countries of Origin |
Based on the results of our RCOI, we have identified the following countries of origin for 3TG necessary to functionality or production of the Covered Products in 2013: Australia, Belgium, Bolivia, Brazil, Burundi, Canada, Chile, China, Czech Republic, Democratic Republic of the Congo, England, Ethiopia, Germany, Hong Kong, India, Indonesia, Japan, Kazakhstan, Korea, Malaysia, Mexico, Mongolia, Mozambique, Nigeria, New Guinea, Peru, Philippines, Portugal, Russia, Rwanda, Spain, Switzerland, Taiwan, Thailand, United Kingdom, United States, Uzbekistan, Vietnam.
Pursuant to our RCOI, some suppliers disclosed to us that recycled or scrap sources of 3TG were identified in their supply chains and do not require due diligence. As such, countries of origin of these recycled or scrap sources may not be included in the foregoing list.
| V. | Facilities Used to Process 3TG |
We have determined that seventy-two of the smelters/refiners used to process the 3TG used in the Covered Products have been validated as conflict free pursuant to the Conflict Free Smelter Program. Based on the information provided by our direct suppliers, the following smelters and refiners with an unknown sourcing status were also used to process 3TG necessary to functionality or production of the Covered Products in 2013. We will continue to engage with our suppliers to determine the source of 3TG processed at the following facilities and to engage in efforts to determine the mine or location of origin of the 3TG used with greater specificity:
Smelter/Refiner Name |
Aida Chemical Industries Co. Ltd. |
Almalyk Mining and Metallurgical Complex (AMMC) |
Asaka Riken Co Ltd |
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
Aurubis AG |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
Boliden AB |
Caridad |
Cendres & Métaux SA |
Central Bank of the DPR of Korea |
Chugai Mining |
Codelco |
Daejin Indus Co. Ltd |
DaeryongENC |
Do Sung Corporation |
FSE Novosibirsk Refinery |
Heimerle + Meule GmbH |
Hwasung CJ Co. Ltd |
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited |
Japan Mint |
Jiangxi Copper Company Limited |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
JSC Uralectromed |
Kazzinc Ltd |
Korea Metal Co. Ltd |
Kyrgyzaltyn JSC |
L’ azurde Company For Jewelry |
Met-Mex Peñoles, S.A. |
Moscow Special Alloys Processing Plant |
Nadir Metal Rafineri San. Ve Tic. A.Ş. |
Navoi Mining and Metallurgical Combinat |
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) |
OJSC Kolyma Refinery |
Pan Pacific Copper Co. LTD |
Prioksky Plant of Non-Ferrous Metals |
PT Aneka Tambang (Persero) Tbk |
PX Précinox SA |
Sabin Metal Corp. |
SAMWON METALS Corp. |
Schone Edelmetaal |
Shandong Zhaojin Gold & Silver Refinery Co. Ltd |
SOE Shyolkovsky Factory of Secondary Precious Metals |
Suzhou Xingrui Noble |
The Great Wall Gold and Silver Refinery of China |
The Refinery of Shandong Gold Mining Co. Ltd |
Torecom |
Umicore Brasil Ltda |
Xstrata Canada Corporation |
Yokohama Metal Co Ltd |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
Zijin Mining Group Co. Ltd |
Gannon & Scott |
CNMC (Guangxi) PGMA Co. Ltd. |
Cookson |
Cooper Santa |
CV Duta Putra Bangka |
CV Gita Pesona |
CV JusTindo |
CV Makmur Jaya |
CV Nurjanah |
CV Prima Timah Utama |
CV Serumpun Sebalai |
CV United Smelting |
EM Vinto |
Fenix Metals |
Geiju Non-Ferrous Metal Processing Co. Ltd. |
Gejiu Zi-Li |
Gold Bell Group |
Huichang Jinshunda Tin Co. Ltd |
Jiangxi Nanshan |
Kai Unita Trade Limited Liability Company |
Linwu Xianggui Smelter Co |
Liuzhou China Tin |
Metallo Chimique |
Minmetals Ganzhou Tin Co. Ltd. |
Novosibirsk Integrated Tin Works |
PT Alam Lestari Kencana |
PT Artha Cipta Langgeng |
PT Babel Inti Perkasa |
PT Babel Surya Alam Lestari |
PT Bangka Kudai Tin |
PT Bangka Putra Karya |
PT Bangka Timah Utama Sejahtera |
PT Bangka Tin Industry |
PT Belitung Industri Sejahtera |
PT BilliTin Makmur Lestari |
PT DS Jaya Abadi |
PT Eunindo Usaha Mandiri |
PT Fang Di MulTindo |
PT HP Metals Indonesia |
PT Karimun Mining |
PT Koba Tin |
PT Mitra Stania Prima |
PT Panca Mega |
PT Refined Banka Tin |
PT Sariwiguna Binasentosa |
PT Seirama Tin investment |
PT Stanindo Inti Perkasa |
PT Sumber Jaya Indah |
PT Timah Nusantara |
PT Tinindo Inter Nusa |
PT Tommy Utama |
PT Yinchendo Mining Industry |
Yunnan Chengfeng |
A.L.M.T. Corp. |
ATI Tungsten Materials |
Chaozhou Xianglu Tungsten Industry Co Ltd |
China Minmetals Nonferrous Metals Co Ltd |
Chongyi Zhangyuan Tungsten Co Ltd |
Dayu Weiliang Tungsten Co., Ltd. |
Fujian Jinxin Tungsten Co., Ltd. |
Ganzhou Grand Sea W & Mo Group Co Ltd |
HC Starck GmbH |
Hunan Chenzhou Mining Group Co |
Hunan Chun-Chang Nonferrous Smelting & Concentrating Co., Ltd. |
Japan New Metals Co Ltd |
Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. |
Jiangxi Rare Earth & Rare Metals Tungsten Group Corp |
Jiangxi Tungsten Industry Group Co Ltd |
Kennametal Inc. |
Tejing (Vietnam) Tungsten Co Ltd |
Wolfram Bergbau und Hütten AG |
Wolfram Company CJSC |
Xiamen Tungsten Co Ltd |
Zhuzhou Cemented Carbide Group Co Ltd |
