EX-1.01 2 ex_115614.htm EXHIBIT 1.01 ex_115614.htm

Exhibit 1.01

 

Spartan Motors, Inc.

Conflict Minerals Report

For the Year Ended December 31, 2017

 

 

This report for the calendar year ended December 31, 2017, is presented to pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the "Rule"). The Rule was adopted by the Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 ("Dodd-Frank Act"). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain tantalum, tin, tungsten or gold, which are necessary to the functionality or production of their products. The term "Conflict Minerals" is defined as columbite-tantalite (coltan), cassiterite, gold, wolframite, tantalum, tin, tungsten, and any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo (DRC) or an adjoining country. The term "3TG" is defined as tantalum, tin, tungsten and gold and their compounds.

 

If a registrant can establish that the 3TG in their supply chain originated from sources other than the Democratic Republic of the Congo or an adjoining country, as defined by the SEC (the "Covered Countries"), or from recycled and scrap sources, they must submit a Form SD which describes the Reasonable Country of Origin Inquiry ("RCOI") that the registrant completed.

 

If a registrant has reason to believe that any of the 3TG in their supply chain may have originated in the Covered Countries, or if they are unable to determine the country of origin of those conflict minerals, then the issuer must exercise due diligence on the conflict minerals' source and chain of custody. The registrant must annually submit a Conflict Minerals Report ("CMR") to the SEC that includes a description of those due diligence measures.

 

Company Overview

Spartan Motors, Inc. is a leading, niche market engineer and manufacturer in the heavy-duty, custom vehicles marketplace. Our operating activities are conducted through our wholly owned operating subsidiary, Spartan Motors USA, Inc. (“Spartan USA”), with locations in Charlotte, Michigan; Brandon, South Dakota; Ephrata, Pennsylvania; Bristol, Indiana; Snyder and Neligh, Nebraska; Delavan, Wisconsin; Kansas City, Missouri; and Saltillo, Mexico. Spartan USA was formerly known as Crimson Fire, Inc.

 

Our Charlotte, Michigan location manufactures heavy duty chassis and vehicles and supplies aftermarket parts and assemblies under the Spartan Chassis and Spartan brand names. Our Brandon, South Dakota, Snyder and Neligh, Nebraska, Delavan, Wisconsin and Ephrata, Pennsylvania locations manufacture emergency response vehicles under the Spartan and Smeal brand names. Our Bristol Indiana location manufactures delivery and service vehicles and supplies related aftermarket parts and services under the Utilimaster brand name, while our Kansas City, Missouri and Saltillo, Mexico locations sell and install equipment used in delivery vehicles.

 

Conflict Minerals Policy

Spartan Motors and its subsidiaries endeavor to maintain the highest standards of ethical conduct and integrity in all areas of their business activities.

 

On August 22, 2012, the U.S. Securities and Exchange Commission adopted final rules to implement reporting and disclosure requirements related to "conflict minerals," as directed by the Dodd-Frank.

 

We are committed to working closely with our supply chain to ensure we fully comply with the requirements set forth in Section 1502 of the Dodd-Frank Act. We have implemented the Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, and are utilizing the conflict minerals reporting template (CMRT) owned by the Conflict Free Sourcing Initiative (CFSI), for exercising due diligence within our supply chain.

 

We do not knowingly source any product containing Conflict Minerals and we continue work on our due diligence process in order to verify that the components we source do not contain Conflict Minerals. We have requested that our suppliers commit to responsible sourcing of 3TG used in the production of components supplied to us. We expect our suppliers to have in place policies and due diligence measures that will enable us to reasonably assure that products and components supplied to us containing 3TG are DRC conflict free. Our suppliers will be requested to perform due diligence to determine the source of any 3TG that are contained in the components that they supply to us. Our suppliers due diligence must include, where applicable, completion of the CFSI Conflict Minerals reporting CMRT.

 

Our conflict minerals policy is posted on our website at http://www.spartanmotors.com/about-us/supplier-info/

 

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RCOI & Due Diligence

Our due diligence measures have been designed to conform with the framework from the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related Supplements for Gold and for Tin, Tantalum and Tungsten ("OECD Guidance").

 

Supply Chain

We rely on our direct suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us, including sources of 3TG that are supplied to them from lower tier suppliers. We have requested that our suppliers commit to responsible sourcing of conflict minerals used in the production of components supplied to us. Our suppliers have been requested to perform due diligence to determine the source of any conflict minerals that are contained in the components that they supply to us. Our suppliers' due diligence must include, where applicable, completion of the CMRT. The CMRT was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company's supply chain. It includes questions regarding a company's conflict-free policy, engagement with its direct suppliers, and a listing of the smelters the company and its suppliers use. In addition, the CMRT contains questions about the origin of conflict minerals included in their products, as well as supplier due diligence. Written instructions and recorded training illustrating the use of the tool is available on CFSI's website.

For the 2017 reporting year, all of our relevant suppliers were asked to complete the CMRT. This is a requirement set forth in all of our supplier contract agreements.

 

Due Diligence Process

We reviewed the components that are included in the specialty vehicles and chassis that we manufacture that could contain 3TG that is necessary to the functionality or production of our products. Our due diligence measures have been designed to conform with the framework in the OECD Guidance.

 

Step One: Establish Strong Company Management Systems

Internal Team

At our corporate level, we have a cross functional team and a third-party consulting subject matter expert working collaboratively to administer our program. This team is responsible for the corporate conflict minerals policy and providing support and instructions on the due diligence measures required to be followed for each of our divisions.

 

Supplier Engagement

With respect to the OECD requirement to strengthen engagement with suppliers, we have continued with our training program for our suppliers for the 2017 reporting by developing an instructional document that was provided to all of our suppliers. We will encourage our suppliers to share this information throughout the whole supply chain, all the way to the smelter level. Suppliers will continue to receive education and support from our business unit champions during the RCOI process and on an annual basis.

 

We have a robust supplier management plan for new and existing suppliers for Conflict Minerals. Existing suppliers must comply with Spartan’s quality manual and Spartan Terms and Conditions which includes Conflict Minerals reporting requirements. In addition, we provide annual education materials, supplier CMRT invitations and utilize a third-party software & consulting Conflict Minerals platform. Internal supplier management processes have also been updated to ensure supplier conformance and communication that include Conflict Minerals reporting requirements when a new supplier is selected. As part of the supplier approval process, new suppliers, unless exempt from Conflict Minerals reporting requirements, must provide a completed CMRT prior to being approved as a Spartan Motors supplier.

 

Spartan Motors provides education materials for suppliers on an annual basis to assist them with their conflict minerals reporting compliance. Compliance with all the criteria is dictated in the contract for all Spartan Motors suppliers.

 

Grievance Mechanism

Our website (http://www.spartanmotors.com/about-us/supplier-info/) contains a link to our conflict minerals policy page. Included with our conflict minerals policy on our website is a link that can be utilized to contact our Compliance Officer with concerns regarding our conflict minerals policy or our use of conflict minerals. It is the policy of Spartan Motors that any communications regarding our Code of Business Conduct and Compliance or Conflict Minerals received by our Chief Compliance Officer is submitted for review to our Board of Directors.

 

Step Two: Identify and Assess Risk in the Supply Chain

All of our relevant suppliers were identified for inclusion in our 2017 RCOI. We rely on these suppliers, whose components we believe may contain 3TG, to provide us with information about the source of Conflict Minerals, if any, contained in the components supplied to us. Our direct suppliers are similarly reliant upon information provided by their suppliers.

 

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We will assess risk by reviewing the suppliers' answers provided in the CMRT for risk indicators that are identified though our third-party Conflict Minerals platform. Risk indicators identified from the CMRT reports are then communicated back to our suppliers for awareness and continuous improvement for future Conflict Minerals reporting requirements.

 

Step Three: Design and Implement a Strategy to Respond to Risks

Relevant suppliers are mandated to provide a CMRT for each reporting year. Supplier CMRTs are evaluated against a set list of data quality standards. Any discrepancies identified are logged in an online tool and sent back to the supplier for further investigation and corrective action.

 

Step Four: Carry Out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain 

We do not typically have a direct relationship with 3TG smelters and refiners and do not perform or direct audits of these entities within our supply chain. We do track all smelters that have been audited via the Conflict Free Sourcing Initiative ("CFSI").

 

 Step Five: Report on Supply Chain Due Diligence

We conducted a survey of those suppliers described above using the CMRT. The CMRT was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company's supply chain. It includes questions regarding a company's conflict-free policy, engagement with its direct suppliers, and a listing of the smelters the company and its suppliers use. In addition, the CMRT contains questions about the origin of 3TG included in their products, as well as supplier due diligence. Written instructions and recorded training illustrating the use of the tool is available on CFSI's website. The CMRT is being used by many companies in their due diligence processes related to conflict minerals.

 

It is our goal to continue to work with our suppliers to educate them on all the requirements so that we can have a marked improvement in response rate. For the 2017 reporting year, we received responses from 22 percent of all the suppliers surveyed. The 2017 data collected included the names of 211 entities listed by our suppliers as smelters or refiners. 160 of these entities were identified as validated to be Conflict-Free by the CFSI. We compared these facilities to the CFSI list of smelters and where a supplier indicated that the facility was certified as Conflict-Free, we ensured that the name was listed by CFSI.

 

The large majority of the responses received provided data at a company or divisional level or were unable to specify the smelters or refiners used. We are unable to determine whether any of the 3TG reported by our suppliers were contained in components or parts supplied to us or to validate that any of these smelters or refiners are actually in our supply chain. Requesting that our suppliers complete the CMRT regarding information about 3TG smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TG in our supply chain.

 

We are committed to this process and will continue to implement and improve our conflict minerals due diligence program. Based on the information obtained pursuant to our RCOI and the due diligence process, we do not have sufficient information to determine the country of origin of the 3TG used in our products.

 

Based on the information that was provided by the responding suppliers and otherwise obtained through our due diligence process; below is the list of smelters and refiners that were provided by our supply chain. Since reporting was completed at a company level we are not able to determine with certainty that these are used in our supply chain. 

 

Smelter Look-up (*)

Smelter Country (*)

Smelter

Identification

Abington Reldan Metals, LLC

UNITED STATES OF AMERICA

CID002708

Advanced Chemical Company

UNITED STATES OF AMERICA

CID000015

Aida Chemical Industries Co., Ltd.

JAPAN

CID000019

Al Etihad Gold LLC

UNITED ARAB EMIRATES

CID002560

Allgemeine Gold-und Silberscheideanstalt A.G.

GERMANY

CID000035

Almalyk Mining and Metallurgical Complex (AMMC)

UZBEKISTAN

CID000041

AngloGold Ashanti Corrego do Sitio Mineracao

BRAZIL

CID000058

Argor-Heraeus S.A.

SWITZERLAND

CID000077

Asahi Pretec Corp.

JAPAN

CID000082

Asahi Refining Canada Ltd.

CANADA

CID000924

 

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Asahi Refining USA Inc.

UNITED STATES OF AMERICA

CID000920

Asaka Riken Co., Ltd.

JAPAN

CID000090

Atasay Kuyumculuk Sanayi Ve Ticaret A.S.

TURKEY

CID000103

AU Traders and Refiners

SOUTH AFRICA

CID002850

Aurubis AG

GERMANY

CID000113

Bangalore Refinery

INDIA

CID002863

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

PHILIPPINES

CID000128

Boliden AB

SWEDEN

CID000157

C. Hafner GmbH + Co. KG

GERMANY

CID000176

Caridad

MEXICO

CID000180

CCR Refinery - Glencore Canada Corporation

CANADA

CID000185

Cendres + Metaux S.A.

SWITZERLAND

CID000189

Chimet S.p.A.

ITALY

CID000233

Chugai Mining

JAPAN

CID000264

Daejin Indus Co., Ltd.

KOREA, REPUBLIC OF

CID000328

Daye Non-Ferrous Metals Mining Ltd.

CHINA

CID000343

Degussa Sonne / Mond Goldhandel GmbH

GERMANY

CID002867

DODUCO Contacts and Refining GmbH

GERMANY

CID000362

Dowa

JAPAN

CID000401

DSC (Do Sung Corporation)

KOREA, REPUBLIC OF

CID000359

Eco-System Recycling Co., Ltd.

JAPAN

CID000425

Elemetal Refining, LLC

UNITED STATES OF AMERICA

CID001322

Emirates Gold DMCC

UNITED ARAB EMIRATES

CID002561

Fidelity Printers and Refiners Ltd.

ZIMBABWE

CID002515

GCC Gujrat Gold Centre Pvt. Ltd.

INDIA

CID002852

Geib Refining Corporation

UNITED STATES OF AMERICA

CID002459

Gold Refinery of Zijin Mining Group Co., Ltd.

CHINA

CID002243

Great Wall Precious Metals Co., Ltd. of CBPM

CHINA

CID001909

Guangdong Jinding Gold Limited

CHINA

CID002312

Guoda Safina High-Tech Environmental Refinery Co., Ltd.

CHINA

CID000651

Hangzhou Fuchunjiang Smelting Co., Ltd.

CHINA

CID000671

HeeSung Metal Ltd.

KOREA, REPUBLIC OF

CID000689

Heimerle + Meule GmbH

GERMANY

CID000694

Heraeus Metals Hong Kong Ltd.

CHINA

CID000707

Heraeus Precious Metals GmbH & Co. KG

GERMANY

CID000711

Hunan Chenzhou Mining Co., Ltd.

CHINA

CID000767

HwaSeong CJ CO., LTD.

KOREA, REPUBLIC OF

CID000778

Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.

CHINA

CID000801

Ishifuku Metal Industry Co., Ltd.

JAPAN

CID000807

Istanbul Gold Refinery

TURKEY

CID000814

Italpreziosi

ITALY

CID002765

Japan Mint

JAPAN

CID000823

Jiangxi Copper Co., Ltd.

CHINA

CID000855

JSC Ekaterinburg Non-Ferrous Metal Processing Plant

RUSSIAN FEDERATION

CID000927

JSC Uralelectromed

RUSSIAN FEDERATION

CID000929

 

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JX Nippon Mining & Metals Co., Ltd.

JAPAN

CID000937

Kaloti Precious Metals

UNITED ARAB EMIRATES

CID002563

Kazakhmys Smelting LLC

KAZAKHSTAN

CID000956

Kazzinc

KAZAKHSTAN

CID000957

Kennecott Utah Copper LLC

UNITED STATES OF AMERICA

CID000969

KGHM Polska Miedz Spolka Akcyjna

POLAND

CID002511

Kojima Chemicals Co., Ltd.

JAPAN

CID000981

Korea Zinc Co., Ltd.

KOREA, REPUBLIC OF

CID002605

Kyrgyzaltyn JSC

KYRGYZSTAN

CID001029

Kyshtym Copper-Electrolytic Plant ZAO

RUSSIAN FEDERATION

CID002865

L'azurde Company For Jewelry

SAUDI ARABIA

CID001032

Lingbao Gold Co., Ltd.

CHINA

CID001056

Lingbao Jinyuan Tonghui Refinery Co., Ltd.

CHINA

CID001058

L'Orfebre S.A.

ANDORRA

CID002762

LS-NIKKO Copper Inc.

KOREA, REPUBLIC OF

CID001078

Luoyang Zijin Yinhui Gold Refinery Co., Ltd.

CHINA

CID001093

Marsam Metals

BRAZIL

CID002606

Materion

UNITED STATES OF AMERICA

CID001113

Matsuda Sangyo Co., Ltd.

JAPAN

CID001119

Metalor Technologies (Hong Kong) Ltd.

CHINA

CID001149

Metalor Technologies (Singapore) Pte., Ltd.

SINGAPORE

CID001152

Metalor Technologies (Suzhou) Ltd.

CHINA

CID001147

Metalor Technologies S.A.

SWITZERLAND

CID001153

Metalor USA Refining Corporation

UNITED STATES OF AMERICA

CID001157

Metalurgica Met-Mex Penoles S.A. De C.V.

MEXICO

CID001161

Mitsubishi Materials Corporation

JAPAN

CID001188

Mitsui Mining and Smelting Co., Ltd.

JAPAN

CID001193

MMTC-PAMP India Pvt., Ltd.

INDIA

CID002509

Modeltech Sdn Bhd

MALAYSIA

CID002857

Morris and Watson

NEW ZEALAND

CID002282

Morris and Watson Gold Coast

AUSTRALIA

CID002866

Moscow Special Alloys Processing Plant

RUSSIAN FEDERATION

CID001204

Nadir Metal Rafineri San. Ve Tic. A.S.

TURKEY

CID001220

Navoi Mining and Metallurgical Combinat

UZBEKISTAN

CID001236

Nihon Material Co., Ltd.

JAPAN

CID001259

Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH

AUSTRIA

CID002779

Ohura Precious Metal Industry Co., Ltd.

JAPAN

CID001325

OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)

RUSSIAN FEDERATION

CID001326

OJSC Novosibirsk Refinery

RUSSIAN FEDERATION

CID000493

PAMP S.A.

SWITZERLAND

CID001352

Pease & Curren

UNITED STATES OF AMERICA

CID002872

Penglai Penggang Gold Industry Co., Ltd.

CHINA

CID001362

Planta Recuperadora de Metales SpA

CHILE

CID002919

 

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Prioksky Plant of Non-Ferrous Metals

RUSSIAN FEDERATION

CID001386

PT Aneka Tambang (Persero) Tbk

INDONESIA

CID001397

Asaka Riken Co., Ltd.

JAPAN

CID000092

Changsha South Tantalum Niobium Co., Ltd.

CHINA

CID000211

D Block Metals, LLC

UNITED STATES OF AMERICA

CID002504

Duoluoshan

CHINA

CID000410

Exotech Inc.

UNITED STATES OF AMERICA

CID000456

F&X Electro-Materials Ltd.

CHINA

CID000460

FIR Metals & Resource Ltd.

CHINA

CID002505

Global Advanced Metals Aizu

JAPAN

CID002558

Global Advanced Metals Boyertown

UNITED STATES OF AMERICA

CID002557

Guangdong Rising Rare Metals-EO Materials Ltd.

CHINA

CID000291

Guangdong Zhiyuan New Material Co., Ltd.

CHINA

CID000616

H.C. Starck Co., Ltd.

THAILAND

CID002544

H.C. Starck Hermsdorf GmbH

GERMANY

CID002547

H.C. Starck Inc.

UNITED STATES OF AMERICA

CID002548

H.C. Starck Ltd.

JAPAN

CID002549

H.C. Starck Smelting GmbH & Co. KG

GERMANY

CID002550

H.C. Starck Tantalum and Niobium GmbH

GERMANY

CID002545

Hengyang King Xing Lifeng New Materials Co., Ltd.

CHINA

CID002492

Jiangxi Dinghai Tantalum & Niobium Co., Ltd.

CHINA

CID002512

Jiangxi Tuohong New Raw Material

CHINA

CID002842

JiuJiang JinXin Nonferrous Metals Co., Ltd.

CHINA

CID000914

Jiujiang Tanbre Co., Ltd.

CHINA

CID000917

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

CHINA

CID002506

KEMET Blue Metals

MEXICO

CID002539

KEMET Blue Powder

UNITED STATES OF AMERICA

CID002568

LSM Brasil S.A.

BRAZIL

CID001076

Metallurgical Products India Pvt., Ltd.

INDIA

CID001163

Mineracao Taboca S.A.

BRAZIL

CID001175

Mitsui Mining and Smelting Co., Ltd.

JAPAN

CID001192

Ningxia Orient Tantalum Industry Co., Ltd.

CHINA

CID001277

NPM Silmet AS

ESTONIA

CID001200

Power Resources Ltd.

MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF

CID002847

Alpha

UNITED STATES OF AMERICA

CID000292

An Vinh Joint Stock Mineral Processing Company

VIET NAM

CID002703

Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.

CHINA

CID000228

China Tin Group Co., Ltd.

CHINA

CID001070

CNMC (Guangxi) PGMA Co., Ltd.

CHINA

CID000278

CV Ayi Jaya

INDONESIA

CID002570

CV Dua Sekawan

INDONESIA

CID002592

CV Gita Pesona

INDONESIA

CID000306

CV United Smelting

INDONESIA

CID000315

 

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CV Venus Inti Perkasa

INDONESIA

CID002455

Dowa

JAPAN

CID000402

Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company

VIET NAM

CID002572

EM Vinto

BOLIVIA (PLURINATIONAL STATE OF)

CID000438

Estanho de Rondonia S.A.

BRAZIL

CID000448

Fenix Metals

POLAND

CID000468

Gejiu Fengming Metallurgy Chemical Plant

CHINA

CID002848

Gejiu Jinye Mineral Company

CHINA

CID002859

Gejiu Kai Meng Industry and Trade LLC

CHINA

CID000942

Gejiu Non-Ferrous Metal Processing Co., Ltd.

CHINA

CID000538

Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.

CHINA

CID001908

Gejiu Zili Mining And Metallurgy Co., Ltd.

CHINA

CID000555

Guangdong Hanhe Non-Ferrous Metal Co., Ltd.

CHINA

CID003116

Guanyang Guida Nonferrous Metal Smelting Plant

CHINA

CID002849

HuiChang Hill Tin Industry Co., Ltd.

CHINA

CID002844

Huichang Jinshunda Tin Co., Ltd.

CHINA

CID000760

Jiangxi Ketai Advanced Material Co., Ltd.

CHINA

CID000244

Jiangxi New Nanshan Technology Ltd.

CHINA

CID001231

Magnu's Minerais Metais e Ligas Ltda.

BRAZIL

CID002468

Malaysia Smelting Corporation (MSC)

MALAYSIA

CID001105

Melt Metais e Ligas S.A.

BRAZIL

CID002500

Metallic Resources, Inc.

UNITED STATES OF AMERICA

CID001142

Metallo Belgium N.V.

BELGIUM

CID002773

Metallo Spain S.L.U.

SPAIN

CID002774

Mineracao Taboca S.A.

BRAZIL

CID001173

Minsur

PERU

CID001182

Mitsubishi Materials Corporation

JAPAN

CID001191

Modeltech Sdn Bhd

MALAYSIA

CID002858

Nghe Tinh Non-Ferrous Metals Joint Stock Company

VIET NAM

CID002573

O.M. Manufacturing (Thailand) Co., Ltd.

THAILAND

CID001314

O.M. Manufacturing Philippines, Inc.

PHILIPPINES

CID002517

Operaciones Metalurgical S.A.

BOLIVIA (PLURINATIONAL STATE OF)

CID001337

PT Aries Kencana Sejahtera

INDONESIA

CID000309

A.L.M.T. TUNGSTEN Corp.

JAPAN

CID000004

ACL Metais Eireli

BRAZIL

CID002833

Asia Tungsten Products Vietnam Ltd.

VIET NAM

CID002502

Chenzhou Diamond Tungsten Products Co., Ltd.

CHINA

CID002513

Chongyi Zhangyuan Tungsten Co., Ltd.

CHINA

CID000258

Fujian Jinxin Tungsten Co., Ltd.

CHINA

CID000499

Ganzhou Haichuang Tungsten Co., Ltd.

CHINA

CID002645

Ganzhou Huaxing Tungsten Products Co., Ltd.

CHINA

CID000875

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

CHINA

CID002315

Ganzhou Seadragon W & Mo Co., Ltd.

CHINA

CID002494

 

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Ganzhou Yatai Tungsten Co., Ltd.

CHINA

CID002536

Global Tungsten & Powders Corp.

UNITED STATES OF AMERICA

CID000568

Guangdong Xianglu Tungsten Co., Ltd.

CHINA

CID000218

H.C. Starck Smelting GmbH & Co. KG

GERMANY

CID002542

H.C. Starck Tungsten GmbH

GERMANY

CID002541

Hunan Chenzhou Mining Co., Ltd.

CHINA

CID000766

Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji

CHINA

CID002579

Hunan Chunchang Nonferrous Metals Co., Ltd.

CHINA

CID000769

Hunan Litian Tungsten Industry Co., Ltd.

CHINA

CID003182

Hydrometallurg, JSC

RUSSIAN FEDERATION

CID002649

Japan New Metals Co., Ltd.

JAPAN

CID000825

Jiangwu H.C. Starck Tungsten Products Co., Ltd.

CHINA

CID002551

Jiangxi Dayu Longxintai Tungsten Co., Ltd.

CHINA

CID002647

Jiangxi Gan Bei Tungsten Co., Ltd.

CHINA

CID002321

Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.

CHINA

CID002313

Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.

CHINA

CID002318

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

CHINA

CID002317

Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.

CHINA

CID002535

Jiangxi Yaosheng Tungsten Co., Ltd.

CHINA

CID002316

Kennametal Fallon

UNITED STATES OF AMERICA

CID000966

Kennametal Huntsville

UNITED STATES OF AMERICA

CID000105

Malipo Haiyu Tungsten Co., Ltd.

CHINA

CID002319

Moliren Ltd.

RUSSIAN FEDERATION

CID002845

Niagara Refining LLC

UNITED STATES OF AMERICA

CID002589

Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC

VIET NAM

CID002543

Philippine Chuangxin Industrial Co., Inc.

PHILIPPINES

CID002827

 

 

Our efforts to determine the mine or location of origin of the 3TG used in our products consisted of the due diligence measures described in this report. In particular, because independent third party audit programs validate whether sufficient evidence exists regarding country, mine and/or location of origin of the 3TG that the audited smelter or refiner facilities have processed, we relied on the information made available by such programs for the smelters and refiners in our supply chain. We were unable to ascertain the country of origin and/or chain of custody of all necessary 3TG processed by these facilities because, for this reporting period.

 

2017 Improvement Review

Supplier education is a priority for Spartan Motors. We are committed to continuing to educate and support our suppliers and internal staff.

 

Planned Steps to Improve Due Diligence

We intend to take the following steps to improve our due diligence program:

 

1.

Continue to work with suppliers to collect a complete list of smelters within Spartan Motor’s supply chain by providing direction to reference the CFSI list of smelters when completing their CMRT report.

 

2.

Provide education materials to suppliers annually that include instructions and any updates when completing their CMRT reports.

 

3.

Review more efficient ways to accept and review excel version of CMRT

 

8/8