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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(Name and telephone number, including area code, of the
person to contact in connection with this report.) |
OSHKOSH CORPORATION
By /s/ Ignacio A. Cortina
Ignacio A. Cortina
Executive Vice President, Chief Legal Officer and Secretary |
Date May 31, 2023
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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 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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Fire & Emergency – 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.
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•
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Commercial – refuse 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.
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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 2021 to 2022
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a.
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Partnered 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 as well as changes in the timing of our survey activities that created additional time to evaluate our survey responses. 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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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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f.
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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. We also continued to be active participants in the Responsible Minerals Initiative
program for the 2022 reporting period.
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g.
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Proactive outreach – we conducted an outreach initiative with Assent to target all suppliers with any previous connection to a Russian-affiliated smelter with the 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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