Wisconsin
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1-31371
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(State or Other Jurisdiction)
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(Commission file number)
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1917 Four Wheel Drive, Oshkosh, Wisconsin
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54902
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(Address of Principal Executive Offices)
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(Zip Code)
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Ignacio A. Cortina
Executive Vice President, Chief Legal Officer and Secretary
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(920) 502-3023
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☒
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Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the
reporting period from January I to December 31, 2023.
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☐
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Rule 13q-l under the Securities Exchange Act (17 CFR 240.13q-l) for the fiscal year ended ______.
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1.
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Company Overview
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•
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Access Equipment – aerial work platforms and telehandlers used in a wide variety of construction, industrial, institutional
and general maintenance applications to position workers and materials at elevated heights, as well as carriers and wreckers. Access Equipment customers include equipment rental companies, construction contractors, manufacturing companies,
home improvement centers and towing companies.
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•
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Defense – tactical trucks, trailers, supply parts and services sold to the U.S. military and to other militaries around the
world, other specialty vehicles for the U.S. government, as well as, for a portion of 2023, snow removal vehicles for military and civilian airports. In addition, the Defense segment offers engineering and product development services to
customers in the motorsports and multiple ground vehicle markets through Pratt Miller.
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•
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Vocational – (Previously Fire & Emergency and Commercial) custom and commercial firefighting vehicles and equipment,
Aircraft Rescue and Firefighting (ARFF) vehicles, simulators, mobile command and control vehicles and other emergency vehicles primarily sold to fire departments, airports and other governmental units, as well as broadcast vehicles sold to
broadcasters and TV stations. Refuse and recycling collection vehicles sold to commercial and municipal waste haulers, concrete mixers sold to ready-mix companies and field service vehicles and truck-mounted cranes sold to mining,
construction and other companies. Aviation ground support products, gate equipment, and airport services provided to commercial airlines, airports, air-freight carriers, ground handling and military customers.
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2.
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Actions Taken in Support of Our Conflict Minerals Program
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3.
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Reasonable Country of Origin Inquiry and Due Diligence
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4.
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Improvement Actions – Reporting Year 2022 to 2023
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a.
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Continued partnership with Assent Inc. to further enhance our supplier survey process – we utilized Assent’s extensive
supplier database to increase outreach efforts to historically unresponsive suppliers. We conducted a pre-campaign outreach initiative to build awareness for our suppliers on the importance of completing this request. We also used Assent’s
expertise to help educate suppliers on conflict minerals reporting requirements. We managed a multi-tiered follow up campaign to strive for a higher supplier response rate. We also leveraged Assent’s experience to benchmark our process
against their clientele.
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b.
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Data extraction and supplier risk assessment – we improved our ability to identify suppliers that accounted for a significant
amount of our direct material spend. As a result, our supplier survey process was more focused, allowing us to target those specific suppliers whose survey
responses indicated a higher risk of sourcing from a Covered Country. We engaged those suppliers directly in an attempt to determine the specific risk factors in effect and how those risks could best be addressed.
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c.
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Supplier risk escalation/disposition – we continued to refine and utilize our supply chain conflict minerals risk
escalation/disposition process. This step-by-step methodology guides an
individual through the process of identifying and mitigating 3TG risk and includes a process flowchart with decision points and next steps, work instructions, and a checklist of action steps for supply chain personnel to take when a potential
3TG supply chain risk is identified through the supplier survey process. This process is highly tailored toward one-on-one, interpersonal engagement between our personnel and the supplier to ensure any potential risk is fully understood and
appropriate risk mitigation actions are developed.
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d.
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Supplier survey responses - we continued to make improvements to our supplier survey process in an attempt to increase the
response rate and our understanding of the 3TG in our supply chain. These improvements included specific outreach to historically non-responsive suppliers. We used historical data that suppliers provided to create a more targeted follow up
campaign, helping increase our response rate.
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e.
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Supplier inquires – enhancements were made in the supplier inquiry process where we communicated more timely responses and/or
clarifications thereby allowing some historically non-responsive suppliers to provide insight into 3TG usage.
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f.
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Smelter or refiner information – through continued engagement with the Responsible Minerals Initiative, we received more
information from our suppliers for this reporting period regarding smelters or refiners that may be in our supply chain.
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g.
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Best practice benchmarking – we have maintained our participation in both formal and informal peer group discussions and
reviews. We continued to be a participant in AIAG (Automotive Industry Action Group) and MAPI (Manufacturers Alliance for Productivity and Innovation) discussion forums and educational sessions.
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h.
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Proactive outreach – we continued to conduct an outreach initiative with Assent to target all suppliers with any previous
connection to a Russian-affiliated smelter with the continued goal to bring awareness to our suppliers on applicable restrictions and guidelines.
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5.
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Future Actions to Improve Our Conflict Minerals Program
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a.
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Evolve our supplier data management system to increase the reliability of supplier contact information, resulting in higher
response rates.
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b.
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Enhance our data mining and extraction processes to identify potential 3TG risk within our supply chain to improve our ability
to fully disclose, evaluate, and address those risks. This includes a partnership with FRDM (frdm.co) that affords the ability to dig into our multi-tiered supply-chain that normally would not be visible.
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c.
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Further engage suppliers with 3TG content in the products they provide to improve our understanding of their supply chains and
develop risk mitigation steps as appropriate which may include, but is not limited to, product genome analysis software that is currently being implemented.
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d.
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Collaborate internally with team members who own the relationships with historically unresponsive suppliers to educate them on
the importance of 3TG reporting.
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e.
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Continue to exchange information and best practices within the Responsible Minerals Initiative program, AIAG, and MAPI to
increase our understanding of conflict minerals best practices and the smelters or refiners in our supply chain to better understand the ultimate source and conflict status of the minerals in our multi-tiered and complex supply chain.
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f.
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Work with Assent to benchmark results and best practices year over year to improve our solicitation efforts and follow up
procedures, with a goal of continuous response improvement.
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g.
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Continue to work within industry established frameworks, our trade associations, human rights-focused organizations, and other
groups to identify and implement best practices related to conflict minerals.
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