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•	We have structured compliance efforts internally to support supply chain due diligence. Winnebago Industries has developed a team responsible for the conflict minerals program. The team reports to the CFO.

•	We have established a system of controls and supply chain transparency through the adoption and use of due diligence tools created by the Electronic Industry Citizenship Coalition and the Global e‑Sustainability Initiative (“EICC/GeSI”). This included the use the Conflict Minerals Reporting Template (“CMRT”), a supply-chain survey.

•	We identified risks at the product level and determined that all products we produce contained conflict minerals necessary to the functionality of the product.

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We have conducted a supply chain survey of 100% of suppliers that potentially provided parts and materials containing conflict minerals. The survey requested suppliers to identify smelters and refiners, using the CMRT. As a downstream manufacturer, we rely on our vendors to provide the origins of all of our conflict minerals, including the location of the smelter, mine, or transit route of the minerals.

•	We evaluated survey responses to identify: (i) the use and source of Conflict Minerals, and; (ii) any indicators that Conflict Minerals may have come from the Democratic Republic of the Congo or an Adjoining Country.

•	We compared smelters and refiners identified by the supply chain survey against the list of facilities which have received a DRC conflict-free designation from the Conflict Free Smelter Program (“CFSP”).

•	We support the industry associations, which administer independent, third-party smelter audit programs that we rely upon.

•	We made additional inquiries on a case-by-case basis if smelter and refiner information was deemed inconsistent, inaccurate, or incomplete.

•	The status of risk mitigation efforts was summarized and provided to Winnebago Industries’ Management.

•	Our conflict minerals compliance results are reported annually with the SEC and are made publicly available on our website.

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•	Continue to assess the presence of conflict minerals in our supply chain.

•	Clearly communicate expectations with new and delinquent suppliers.

•	Continue to improve our risk mitigation strategy.

•	Continue to encourage our direct suppliers to assess their supply chain risks.

•	Continue to encourage our direct suppliers to provide complete and accurate information.

•	Encourage the implementation of third-party audits of smelters and refiners.

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