THO Thor Industries

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT

THOR Industries, Inc.

(Exact Name of Registrant as Specified in Charter)

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:

☒ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023.

☐ Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the reporting period from January 1 to December 31, 2023.

Section 1 – Conflict Minerals Disclosure

This Form SD of THOR Industries, Inc. (“THOR”, the “Company,” “we”, “our” or “us”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), for the reporting period from January 1, 2023 to December 31, 2023.

Rule 13p-1 requires disclosure of certain information when a company manufacturers or contracts to manufacture products and the minerals specified in the rule are necessary to the functionality or production of those products. The specified minerals are cassiterite, columbite-tantalite (coltan), gold, wolframite, or their derivatives, which are limited to tantalum, tin and tungsten (collectively, the “Conflict Minerals”).

Conflict Minerals Disclosure

We have adopted a policy statement on conflict minerals that is publicly available on our website at http://ir.thorindustries.com (in the “Governance Documents” section).

A copy of this Form SD, including the THOR Industries, Inc. Conflict Minerals Report as filed and attached hereto as Exhibit 1.01, is publicly available at http://ir.thorindustries.com.

The content of any website referred to in this Form SD or the attached Conflict Minerals Report, and any information accessible through any such website, is included for general information only and is not incorporated by reference in this Form SD or the attached Conflict Minerals Report, nor deemed filed with the Securities and Exchange Commission.

As specified in Section 3, Item 3.01, the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this Form SD.

Section 2 – Resource Extraction Issuer Disclosure

Not Applicable

Section 3 – Exhibits

The following exhibit is filed as part of this Form SD:

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.

Exhibit 1.01

THOR INDUSTRIES, INC.

Conflict Minerals Report

For the Year Ended December 31, 2023

This is the Conflict Minerals¹ Report (the “Report”) of THOR Industries, Inc. (“THOR”, the “Company”, “we”, “us”, or “our”) for the reporting period January 1, 2023 to December 31, 2023 pursuant to Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934, as amended, (the “Act”).

COMPANY AND PRODUCT OVERVIEW

THOR, through its operating subsidiaries, manufactures a wide variety of recreational vehicles and component parts in the United States and Europe and sells those vehicles and components, as well as related parts and accessories, primarily to independent, non-franchise dealers throughout the United States, Canada, and Europe.

For calendar year 2023, our recreational vehicle operating subsidiaries included:

THOR is also the sole member of Postle Operating, LLC, a producer of extruded aluminum and specialized components for the recreational vehicle and other industries. THOR is also the sole shareholder of Airxcel, Inc. Airxcel manufactures a comprehensive line of high-quality RV products which are sold to original equipment manufacturers as well as consumers via aftermarket sales through dealers and retailers. Airxcel’s brands include Aqua-Hot, CAN, Coleman-Mach, DICOR Products, United Shade, Velarium, InVision, Vixen Composites, Maxxair, MCD, Seal Design, Cleer Vision Windows, and Elkhart Composites. For purposes of this Report, any reference to products manufactured by or supplied to THOR shall include those products manufactured by and supplied to THOR’s operating subsidiaries.

The majority of THOR’s operating subsidiaries manufacture towable and motorized recreational vehicles. Our subsidiaries’ manufacturing processes mainly consist of the assembly of units and utilize products that may include, but are not limited to, electronics, electronic components, chassis, upholstery, flooring products, wood and wood-based products, adhesives, paint, mirrors, glass, plastic, fiberglass, plumbing components, heating and cooling components, furniture, aluminum, steel, extruded polystyrene, appliances, and other similar products. Postle Operating, LLC’s offerings include aluminum extrusions, powder coating and painting services, and specialized component fabrication and utilize products that may include, but are not limited to, aluminum, paint, steel, and other similar products. Airxcel provides industry-leading products in recreational vehicle heating, cooling, ventilation, cooking, window covering, side wall, window, awning, appliances, and roofing materials.

In accordance with the Rule, THOR undertook efforts to determine whether the necessary Conflict Minerals in our products were sourced from the Democratic Republic of the Congo (the “DRC”) or an adjoining country. We designed our efforts in conformity with the internationally recognized due diligence framework in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas² (“OECD Due Diligence Guidance”) and related Supplements.

THOR’s efforts also utilized multi-industry initiatives with the smelters and refiners of minerals who may provide those minerals to companies in THOR’s supply chain. THOR, as a purchaser of component parts, is many steps removed from the smelters and refiners that process minerals and ore. THOR does not purchase raw ore or unrefined Conflict Minerals and does not engage in business in the DRC or adjoining countries or purchase Conflict Minerals directly in those countries. As a result, THOR relies on its suppliers to provide origin information on Conflict Minerals contained in components or materials supplied to the Company. Similarly, our direct suppliers may rely on their suppliers for such information.

The statements below are based on the due diligence activities performed to date and in good faith by THOR and are based on the infrastructure and information available at the time of this filing. There are factors that could affect the accuracy of these statements, which factors include, but are not limited to, incomplete supplier data or available smelter and refiner data, errors or omissions by suppliers or smelters and refiners, evolving definition and confirmation of smelters and refiners, incomplete information from industry or other third-party sources, continuing guidance regarding the Rule and Form SD, and other issues.

REASONABLE COUNTRY OF ORIGIN INQUIRY

THOR conducted a good faith reasonable country of origin inquiry (“RCOI”) to determine whether Conflict Minerals supplied to our Company originated in the DRC or an adjoining country or were from recycled or scrap sources, in accordance with Form SD and related guidance provided by the Securities and Exchange Commission (“SEC”). However, our ability to determine the origin and chain of custody of Conflict Minerals is limited. While certain of our suppliers were able to identify the countries of origin of the tin, tantalum, tungsten, and/or gold included in the products that they sell to our subsidiaries, our due diligence efforts did not result in sufficient information to conclusively determine all of the countries of origin of the minerals in our products or to conclusively list relevant countries of origin. Based on our due diligence process and the information received, Annex I contains the list of the smelters and refiners of the tin, tantalum, tungsten and/or gold present in and necessary to the functionality of products (or components thereof) manufactured by THOR’s relevant subsidiaries in the year ended December 31, 2023 who were identified in the reports submitted by our suppliers.

THOR’s efforts include:

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DUE DILIGENCE MEASURES PERFORMED BY THOR

THOR designed its overall Conflict Minerals program based on the five-step framework of the OECD Due Diligence Guidance, the Supplement on Tin, Tantalum, and Tungsten, and the Supplement on Gold.

Step 1: Establish Strong Company Management Systems

Step 2: Identify and Assess Risks in the Supply Chain

THOR engaged in a good-faith RCOI as described above to determine whether the necessary Conflict Minerals originated in the DRC or an adjoining country or were from recycled or scrap sources. With respect to the suppliers that indicated that their products contained Conflict Minerals that originated in the DRC or an adjoining country, THOR verified that the smelters and refiners identified by those suppliers are certified as conflict-free by the Conflict Free Smelter Program established by the EICC/GeSI. With respect to other suppliers, the Company is continuing the process of comparing the identified smelters and refiners with the EICC/GeSI’s list of conflict-free smelters and refiners, beginning with the suppliers whose products the Company determined are most likely to contain Conflict Minerals.

Step 3: Design and Implement a Strategy to Respond to Identified Risks

As part of the risk mitigation process, the Platform compares the smelters/processors collected from vendors to the conflict-free smelter lists published by the EICC/GeSI.

Step 4: Carry Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

THOR is a downstream manufacturer and is many steps removed from smelters and refiners who process minerals and ore. THOR does not purchase raw ore or unrefined Conflict Minerals. THOR supports the audits of smelters and refiners, but does not perform or direct audits of smelters and refiners within its supply chain and relies on its third-party service provider to verify the conflict-free status of smelters and refiners that source from the DRC or adjoining countries.

Step 5: Report on Supply Chain Due Diligence

This Conflict Minerals Report has been filed with the SEC and is publicly available on our website, http://ir.thorindustries.com. THOR’s Conflict Minerals Policy is also available to the public on our website, http://ir.thorindustries.com (in the “Governance Documents” section).

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DUE DILIGENCE RESULTS

Through requesting our suppliers to complete the Conflict Minerals Reporting Template, we determined that seeking information about Conflict Minerals used by smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the Conflict Minerals in our supply chain. Most of our supplier responses were provided at a company level. Many suppliers did not provide verifiable smelter or processing information or responded at a company-wide level which did not allow us to conclude that the Conflict Minerals were processed by any one particular facility. Based on the information provided by our suppliers, we could not identify how many of these smelters produced materials specifically used in our products. Therefore, it is possible that none of the materials from these smelters actually entered our supply chain.

STEPS TO IMPROVE DUE DILIGENCE

We continue to communicate our expectations and information requirements to our vendors. We also continue to monitor changes in circumstances that may impact relevant facts or our determinations. Over time, the amount of information available globally on the traceability and sourcing of covered ores has increased and improved our knowledge and we anticipate this will continue in the future. We continue to make inquiries of our vendors and undertake additional risk assessments when potentially relevant changes in facts or circumstances are identified. If we become aware of a vendor that needs improvement in its due diligence process, we intend generally to continue the trade relationship while that vendor improves its compliance program. We expect our vendors to take similar measures with their suppliers to ensure alignment throughout the supply chain.

In addition to the measures described above, the Company has and will continue to undertake to review and enhance the reporting process as necessary to improve suppliers’ ability to accurately respond. We will continue to seek to improve our own internal supplier identification to improve proficiency in the inquiry and reporting process. The Company has taken steps to ensure Conflict Minerals’ compliance is a part of the standard terms required in all supply arrangements.

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Annex I

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