Exhibit 1.02
Conflict Minerals Report of Polaris Industries Inc.
This is the Conflict Minerals Report of Polaris Industries Inc. (“Polaris,” the “Company”, “we” or “us”) for calendar year 2013 in accordance with Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934 (the “1934 Act”).
Certain Polaris products contain materials that use tin, tantalum, tungsten and/or gold (collectively “3TG”). Due to the depth of the supply chain, we are far removed from the sources of ore from which these metals are produced and the smelters/refiners that process those ores. Accordingly, the efforts we have undertaken to identify the countries of origin of those ores reflect our circumstances and position in the supply chain. The amount of information available globally on the traceability and sourcing of these ores is limited at this time. We have taken steps to identify the applicable smelters and refiners of such 3TG metals in our supply chain. The efforts were undertaken on the products manufactured by us in 2013. This report excludes products manufactured by companies that we do not consolidate into our consolidated financial statements and companies which we acquired after April 30, 2012.
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| II. | Reasonable Country of Origin Inquiry (RCOI) |
Direct suppliers were asked to provide answers to the Electronic Industry Citizenship Coalition-Global e-Sustainability Initiative (EICC-GeSI) Conflict Minerals Common Reporting Template. 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 brands.
We reviewed questionnaires we received from our direct suppliers for completeness and consistency of answers. Certain suppliers were requested to provide corrections and clarifications as needed. We identified a list of smelters/refiners, and their countries of origin, which may supply 3TG utilized in our manufactured products. As many of the responses received from our suppliers were at a level higher than only those products procured to us, it is possible that the list includes smelters/refiners which do not provide 3TG that are utilized in our manufactured products. While we believe our RCOI process was reasonably designed and performed in good faith, as we did not receive responses from all inquired suppliers the list of smelters/refiners set forth below may be incomplete.
The list of smelters/refiners, and their countries or origin, is listed in Section VIII of this Conflict Minerals Report. Through our RCOI process, some suppliers disclosed to us that scrap sources of 3TG were identified in their supply chains and did not require due diligence. These sources are excluded from the listing in Section VIII.
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| III. | Design of Due Diligence Measures |
We designed our due diligence measures to conform in all material respects 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.
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| IV. | Due Diligence Measures Performed |
The due diligence measures performed includes, but are not limited to the following:
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| • | Developed and executed a risk-based process to identify direct suppliers which may procure parts and components to us which contain 3TG and to inquire upon such suppliers to allow for the identification of potential 3TG smelters/refiners within our supply chain; |
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| • | Reported 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; |
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| • | Communicated our policy on Conflict Minerals to direct suppliers; |
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| • | Communicated the commitments and requirements expected of our suppliers; |
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| • | Developed a risk mitigation plan that allows for continued trade with a supplier during the supplier’s risk mitigation efforts; |
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| • | Supported 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. |
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| • | Reported within Form SD the results of our due diligence measures |
We design, engineer and manufacture Off-Road Vehicles, Snowmobiles, Motorcycles and Small Vehicles, together with the related replacement Parts, Garments and Accessories. Many of our products are manufactured utilizing similar processes and similar components. Our suppliers often supply parts and components that are utilized in multiple product categories.
As a result of the due diligence procedures described above, Polaris has determined that our products are DRC conflict undeterminable.
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| VI. | Steps to Improve Due Diligence |
We have and will continue to communicate our expectations and information requirements to our direct suppliers. We have and 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 globally on the traceability and sourcing of the applicable ores will increase and improve our knowledge. We will continue to make inquiries to our direct suppliers and undertake additional fact and risk assessments where potentially relevant changes in facts or circumstances are identified. New suppliers will be reviewed for conflict minerals conformance during initial business reviews. If we become aware of a supplier whose due diligence needs improvement, we intend to continue the trade relationship while that supplier improves its performance. We expect our suppliers to take similar measures with their suppliers to ensure alignment throughout the supply chain.
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| VII. | Independent Private Sector Audit |
Not required for calendar year 2013.
VIII. List of Smelters/Refiners
Section II discusses the process we used to identify potential smelters/refiners within our supply chain. The following is a list of smelters/refiners, and their countries of origin, reported by our suppliers which may supply 3TG utilized in our manufactured products:
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| Smelters/Refiners Identified |
| Smelter/Refiner Name (1) | Sourcing Status |
| Aida Chemical Industries Co. Ltd. | Unknown |
| Almalyk Mining and Metallurgical Complex (AMMC) | Unknown |
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| Smelters/Refiners Identified |
| Smelter/Refiner Name (1) | Sourcing Status |
| Asaka Riken Co Ltd | Unknown |
| Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Unknown |
| Aurubis AG | Unknown |
| Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Unknown |
| Boliden AB | Unknown |
| Caridad | Unknown |
| Cendres & Métaux SA | Unknown |
| Chongyi Zhangyuan Tungsten Co Ltd | Unknown |
| Chugai Mining | Unknown |
| CNMC (Guangxi) PGMA Co. Ltd. | Unknown |
| Cooper Santa | Unknown |
| CV Serumpun Sebalai | Unknown |
| CV United Smelting | Unknown |
| Daejin Indus Co. Ltd | Unknown |
| DaeryongENC | Unknown |
| Do Sung Corporation | Unknown |
| EM Vinto | Unknown |
| Fenix Metals | Unknown |
| FSE Novosibirsk Refinery | Unknown |
| Ganzhou Huaxing Tungsten Products Co., Ltd. | Unknown |
| Ganzhou Non-ferrous Metals Smelting Co., Ltd. | Unknown |
| Gejiu Zi-Li | Unknown |
| Guangdong Xianglu Tungsten Industry Co., Ltd. | Unknown |
| HC Starck GmbH | Unknown |
| Huichang Jinshunda Tin Co. Ltd | Unknown |
| Hunan Chenzhou Mining Group Co | Unknown |
| Hunan Chun-Chang Nonferrous Smelting & Concentrating Co., Ltd. | Unknown |
| Hwasung CJ Co. Ltd | Unknown |
| Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | Unknown |
| Japan Mint | Unknown |
| Japan New Metals Co Ltd | Unknown |
| Jiangxi Copper Company Limited | Unknown |
| Jiangxi Nanshan | Unknown |
| JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Unknown |
| JSC Uralectromed | Unknown |
| Kai Unita Trade Limited Liability Company | Unknown |
| Kazzinc Ltd | Unknown |
| Kennametal Huntsville | Unknown |
| King-Tan Tantalum Industry Ltd | Unknown |
| Korea Metal Co. Ltd | Unknown |
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| Smelters/Refiners Identified |
| Smelter/Refiner Name (1) | Sourcing Status |
| Kyrgyzaltyn JSC | Unknown |
| L' azurde Company For Jewelry | Unknown |
| Linwu Xianggui Smelter Co | Unknown |
| Liuzhou China Tin | Unknown |
| Metallo Chimique | Unknown |
| Met-Mex Peñoles, S.A. | Unknown |
| Minmetals Ganzhou Tin Co. Ltd. | Unknown |
| Moscow Special Alloys Processing Plant | Unknown |
| Nadir Metal Rafineri San. Ve Tic. A.Ş. | Unknown |
| Navoi Mining and Metallurgical Combinat | Unknown |
| Novosibirsk Integrated Tin Works | Unknown |
| OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) | Unknown |
| OJSC Kolyma Refinery | Unknown |
| Prioksky Plant of Non-Ferrous Metals | Unknown |
| PT Aneka Tambang (Persero) Tbk | Unknown |
| PT Artha Cipta Langgeng | Unknown |
| PT Babel Inti Perkasa | Unknown |
| PT Bangka Putra Karya | Unknown |
| PT Bangka Tin Industry | Unknown |
| PT Belitung Industri Sejahtera | Unknown |
| PT DS Jaya Abadi | Unknown |
| PT Eunindo Usaha Mandiri | Unknown |
| PT Karimun Mining | Unknown |
| PT Mitra Stania Prima | Unknown |
| PT Prima Timah Utama | Unknown |
| PT REFINED BANGKA TIN | Unknown |
| PT Sariwiguna Binasentosa | Unknown |
| PT Stanindo Inti Perkasa | Unknown |
| PT Tinindo Inter Nusa | Unknown |
| PX Précinox SA | Unknown |
| Sabin Metal Corp. | Unknown |
| SAMWON METALS Corp. | Unknown |
| Schone Edelmetaal | Unknown |
| Shandong Zhaojin Gold & Silver Refinery Co. Ltd | Unknown |
| SOE Shyolkovsky Factory of Secondary Precious Metals | Unknown |
| Tejing (Vietnam) Tungsten Co., Ltd. | Unknown |
| The Great Wall Gold and Silver Refinery of China | Unknown |
| The Refinery of Shandong Gold Mining Co. Ltd | Unknown |
| Torecom | Unknown |
| Umicore Brasil Ltda | Unknown |
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| Smelters/Refiners Identified |
| Smelter/Refiner Name (1) | Sourcing Status |
| Wolfram Bergbau und Hütten AG | Unknown |
| Wolfram Company CJSC | Unknown |
| Xiamen Tungsten Co., Ltd | Unknown |
| Yokohama Metal Co Ltd | Unknown |
| Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. | Unknown |
| Zhongyuan Gold Smelter of Zhongjin Gold Corporation | Unknown |
| Zhuzhou Cemented Carbide Group Co Ltd | Unknown |
| Zijin Mining Group Co. Ltd | Unknown |
| 71 smelters/refiners listed in the Conflict Free Smelter Program | Validated as Conflict Free (2) |
Countries of origin of the conflict minerals the facilities listed above process are believed to include: Australia, Belgium, Bolivia, Brazil, Canada, Chile, England, Estonia, Ethiopia, Germany, Hong Kong, India, Indonesia, Japan, Kazakhstan, Korea, Malaysia, Mexico, Mozambique, Nigeria, Peru, Russia, Rwanda, South Africa, Switzerland, Taiwan, Thailand, The Democratic Republic of the Congo, United States of America, Uzbekistan and Zimbabwe
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(1) Smelter and refiner facility names as reported by the Conflict-Free Sourcing Initiative as of May 26, 2014.
(2) These smelters and refiners have received a "conflict free" designation from an independent third party audit program as of May 26, 2014. |
