In order to determine whether any Conflict Minerals were necessary to the functionality or production of the products Accuride manufactured during 2013, the reporting period covered by this report, the Company formed a due diligence team that (i) surveyed business unit personnel, (ii) reviewed drawings and specifications, (iii) surveyed Company suppliers, and (iv) tested and analyzed certain constituent raw materials and components to its products. As part of this process, Accuride implemented a broader supply-chain diligence program that surveys suppliers of direct material (materials that go into the products manufactured by Accuride) using the EICC/GeSI Conflict Minerals Reporting Template. This survey was primarily conducted through the iPoint Conflict Minerals Platform, and resulted in responses from approximately 70% of direct material suppliers for Accuride’s Wheels and Gunite operating segments, which represented approximately 95% of the direct material spend by these businesses in 2013. In addition, Accuride engaged in direct communications with suppliers responding through the iPoint platform (or other means) as necessary to attempt to generate a supplier response and/or clarify responses received. Accuride intends to continue to monitor its supply chain in order to remain in compliance with applicable rules and regulations related to Conflict Minerals. As a result of these multi-faceted efforts, Accuride identified tin as an ingredient to certain paint used to coat some of its steel wheel products.
In accordance with the Rule and pursuant to Form SD, Accuride conducted in good faith a “reasonable country of origin inquiry” (“RCOI”), which was reasonably designed to determine whether the tin contained in paint used to coat some of Accuride’s steel wheel products originated in the DRC. As part of its RCOI, Accuride (i) surveyed suppliers of paint to its Wheels and Gunite businesses to determine whether their products included tin or any other Conflict Minerals, (ii) engaged in a series of communications with each vendor whose paint supplied to Accuride was identified as including tin as an ingredient, and (iii) received representations of each such vendor that such tin did not originate in the DRC or an adjoining country.
Based on its RCOI described above, Accuride has determined that the tin contained in the paint used in the production of certain steel wheels that it manufactures did not originate in the DRC or an adjoining country and it has no reason to believe the tin was sourced in the DRC or an adjoining country.