The Toro Company
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(Exact name of registrant as specified in its charter)
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Delaware
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1-8649
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(State or other jurisdiction of incorporation)
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(Commission File Number)
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8111 Lyndale Avenue South
Bloomington, Minnesota
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55420
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(Address of principal executive offices)
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(Zip Code)
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Colleen Hart (952) 888-8801
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(Name and telephone number, including area code,
of the person to contact in connection with this report.)
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☒ |
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2021.
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☐ |
Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended __________________________.
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Item 1.01 |
Conflict Minerals Disclosure and Report
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Item 1.02 |
Exhibit
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Item 2.01 |
Resource Extraction Issuer Disclosure and Report
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Item 2.02 |
Exhibit
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Item 3.01 |
Exhibits
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Exhibit No.
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Description
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Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.
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THE TORO COMPANY
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(Registrant)
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Date: May 31, 2022
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By:
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/s/ Amy E. Dahl
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Amy E. Dahl
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Vice President, Human Resources, and General Counsel
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I. |
Introduction
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II. |
Company Management Systems
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A. |
Conflict Minerals Policy
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B. |
Internal Management Team
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C. |
Control Systems
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D. |
Supplier Engagement
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E. |
Records Management
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F. |
Grievance Mechanism
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G. |
Carry Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
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H. |
Report on Supply Chain Due Diligence
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III. |
Reasonable Country of Origin Inquiry
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A. |
In-Scope Suppliers
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B. |
Request for Information
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C. |
Survey Responses
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D. |
Risk Assessment
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IV. |
Design of Due Diligence Framework
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V. |
Due Diligence Measures
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VI. |
Product Status and Information
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• |
professional turf maintenance equipment
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• |
turf irrigation systems
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landscaping equipment and lighting
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agricultural micro-irrigation systems
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rental and specialty construction equipment
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residential yard and snow thrower products
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professional snow and ice management products
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underground construction products
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VII. |
Identified Smelters and Refiners
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Conformant (231)
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Active (17)
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Other (173)
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Non-DRC
Region Sourced
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DRC Region
Sourced
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R/S
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Low Risk
Country Sourced
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High Risk
Country Sourced
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Gold
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97
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2
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31
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16
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4
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6 |
97
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Tantalum
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15
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21
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25
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30
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22
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0 |
6
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Tin
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48
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6
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23
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25
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6
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7 |
59
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Tungsten
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30
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12
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22
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11
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12
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4 |
11
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(a) |
The smelters and refiners reflected in the table were identified by our suppliers as potentially being part of our supply chain. However, not all of the included smelters and refiners are believed by us to have processed the necessary 3TG
contained in the in-scope products that we manufacture, since the large majority of our suppliers reported to us at a “company level” the 3TG contained in all of their products, not just those in the products that they sold to us. Some
suppliers may have reported to us smelters and refiners that were not in their supply chain due to over-inclusiveness in the information received from their suppliers or for other reasons. In addition, the smelters and refiners reflected above
may not be all of the smelters and refiners in our supply chain, since many suppliers were unable to identify all of the smelters and refiners used to process the necessary 3TG content contained in the in-scope products that we manufacture and
not all of the suppliers responded to our inquiries.
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(b) |
All compliance status information in the table is as of May 5, 2022.
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(c) |
“Conformant” means that an “Eligible” or “Provisionally Eligible” smelter or refiner was audited and found to conform with the Responsible Minerals Assurance Process’ (“RMAP”) assessment protocols.
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(d) |
“Active” means that an “Eligible” smelter or refiner is engaged in the RMAP but has not yet been found to be conformant.
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(e) |
“Other” includes those “Eligible,” “Provisionally Eligible,” “Alleged,” and “Group Company” smelters or refiners with an audit status other than Conformant or Active, including “Communication Suspended – Not Interested”, “RMI Due Diligence
Review – Unable to Proceed”, “Due Diligence Vetting Process, “In Communication”, “Non Conformant”, “Outreach Required” and “Not Applicable.” TTC, through its membership in the RMI, supports efforts to bring these smelters or refiners into the
RMAP audit program.
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(f) |
“DRC Region” means the DRC and its nine adjoining countries. Origin information was derived from information made available by the RMI to its members. According to this information, some of the Conformant smelters and refiners may have
sourced from both within the DRC Region and outside the DRC Region. For these smelters and refiners, we were not able to determine the country of origin of the 3TG specific to our products. Therefore, not all of the country of origin
information reflected in the table may apply to the necessary 3TG contained in the in-scope products that we manufactured. If a smelter or refiner sourced from multiple sources, it is included in the table under each applicable category.
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(g) |
“R/S” means the reported facility processes recycled or scrap material.
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(h) |
16 countries were identified by smelters and refiners as “low risk” in the data compiled by RMI and provided to its members. 19 countries were identified by smelters and refiners as “high risk” in the data compiled by RMI and provided to its
members. Certain countries were identified by some smelters and refiners as “low risk” but disclosed by other smelters and refiners as “high risk.” Based upon the way data is reported to TTC by its suppliers and the manner in which aggregated
Country of Origin data is provided by RMI to its members, we are unable to determine whether the 3TG contained in the in-scope products we manufacture originated in low- risk or high-risk countries.
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(i) |
The compliance status and origin reflected in the table is based solely on information made available by the RMI to its members, without independent verification by us.
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(j) |
We were not able to determine the country of origin of the 3TG processed by any of the smelters or refiners listed as “Active” or “Other.”
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