EX-1.02 2 conflictmineralsreportv4.htm EX-1.02 ConflictMineralsReportv4

Exhibit 1.02
Conflict Minerals Report of Polaris Industries Inc.
I.
Introduction
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.

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.

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.

IV.
Due Diligence Measures Performed
The due diligence measures performed includes, but are not limited to the following:
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;
Communicated our policy on Conflict Minerals to direct suppliers;
Communicated the commitments and requirements expected of our suppliers;
Developed a risk mitigation plan that allows for continued trade with a supplier during the supplier’s risk mitigation efforts;
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.
Reported within Form SD the results of our due diligence measures

V.
Product Description
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.

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.

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:
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


(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.


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