livestock producers, high-value crop producers, and turf and utility customers. The segment’s primary products include certain mid-size and small tractors, as well as hay and forage equipment, riding and commercial lawn equipment, golf course equipment, and utility vehicles. The construction and forestry segment defines, develops, and delivers a broad range of machines and technology solutions organized along earthmoving, forestry and roadbuilding production systems. The segment’s primary products include crawler dozers and loaders, four-wheel-drive loaders, excavators, skid-steer loaders, milling machines, and log harvesters.
As a result of the due diligence procedures described in Section IV below, the Company believes the equipment products described above contain In-Scope Components.
The Company conducted a good faith RCOI to determine whether conflict minerals found in its products may have originated in the Covered Countries and did not come from recycled or scrap sources. The Company used the CMRT to obtain information regarding the smelters and refiners that provide materials to its supply chain. The Company received responses from suppliers representing 98% of the volume for In-Scope Components that may contain conflict minerals. Based on the RCOI, the Company believes that some of the conflict minerals necessary to the production or functionality of its equipment manufactured in the Reporting Period may have originated in the Covered Countries and may not be from recycled or scrap sources (the “Covered Minerals”).
Section III: Design Due Diligence Framework
The Company’s conflict minerals due diligence management system is designed in conformance with the OECD Guidelines. The OECD Guidelines are the framework for a risk-based approach to due diligence for responsible supply chains of conflict minerals. The Company follows this framework through the steps identified in Section IV.
Section IV: Due Diligence Measures Performed
Establish Strong Company Management System
The Company’s Conflict Minerals Policy establishes the principles regarding the responsible sourcing of conflict minerals against which the Company can assess itself and its suppliers. To enforce the Conflict Minerals Policy, the Company has put in place internal supply management systems and controls. The Company’s management structure consists of three levels of oversight.
In accordance with the OECD Guidelines, at the top of the management structure is an executive sponsor. The executive sponsor is a member of the Company’s senior management team. The second level of management is comprised of an executive-level officer and managers from the following functions: supply management environmental, social, and governance; energy and product sustainability; electronic solutions; and legal. This committee provided guidance and oversight to the third level of the management system for conflict minerals. The third level of the management system is a team of subject matter experts (“CM Team”) from relevant functions within the Company, including supply management compliance and sustainability, environmental, information technology, and legal. The CM Team is responsible for implementing the Company’s due diligence procedures. In accordance with the Company’s Conflict Minerals Policy and the OECD Guidelines, the Company will maintain, and will require In-Scope Suppliers (as defined below) to maintain, conflict minerals records for five years.
Identify and Assess Risks in the Supply Chain
Due to the size and complexity of John Deere’s global supply chain as well as its considerable number of suppliers, products, parts and components, a process was developed to assess and remove parts not containing conflict minerals from the inquiry. The RCOI pertains only to suppliers of In-Scope Components (“In-Scope Suppliers”) introduced into John Deere’s supply chain during the Reporting Period. In-Scope Components include all parts in Material Group Codes (internal material identification and tracking codes) that could potentially contain conflict minerals. Parts, components, or products not containing conflict minerals were excluded from further inquiry.
The Company’s RCOI is comprised of three processes: the first collects information on the Company’s equipment components (“Equipment Survey”); the second collects information on the Company’s electronics components (“Electronics Survey”); and the third collects information on the Company’s after-market parts division (“All-Makes Survey” and, collectively with the Equipment Survey and the Electronics Survey, the “Surveys”). In each case, the Surveys cover In-Scope Suppliers of In-Scope Components during the Reporting Period.