Form: SD

Specialized disclosure report

Documents

EXHIBIT 1.02

DORMAN PRODUCTS, INC.

Conflict Minerals Report

Introduction

This Conflict Minerals Report (the “Report”) of Dorman Products, Inc. (the “Company”, “we”, “us”, or “our” refers to Dorman Products, Inc. and its subsidiaries) has been prepared pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2013 to December 31, 2013.

The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals, which are collectively referred to in this report as “Conflict Minerals,” are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten. The “Covered Countries” for the purposes of the Rule and this Report are the Democratic Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. As described in this Report, Conflict Minerals are necessary to the functionality of certain of the Company’s products that the Company contracts to manufacture.

The Company has adopted a Conflict Minerals Policy Statement (the “Company Policy”). The Company Policy provides that (i) the Company supports the effort to end the human rights violations and violence in the Covered Countries; (ii) it is the goal of the Company to procure products that are certified as “conflict free;” and (iii) the Company will work diligently to ensure compliance with this commitment and will undertake reasonable due diligence within its supply chain to ensure that all of its vendors support this effort. A copy of the Company Policy is available at www.dormanproducts.com. The content of any website referred to in this Report is included for general information only and is not incorporated by reference into this Form SD.

Description of the Company and the Products Covered by this Report

The Company is a supplier of replacement parts and fasteners for passenger cars, light trucks and heavy duty trucks in the automotive aftermarket, many of which the Company designs and engineers. The Company groups its products into four major classes (the “Product Groups”): power-train, automotive body, chassis, and hardware. The power-train product line includes intake and exhaust manifolds, cooling products, harmonic balancers, fluid lines, fluid reservoirs, connectors, 4 wheel drive components and axles, drain plugs, and other engine, transmission and axle components. Automotive body products include door handles and hinges, window lift motors, window regulators, switches and handles, wiper components, lighting, electrical, and other interior and exterior automotive body components. Chassis products include brake hardware and hydraulics, wheel and axle hardware, suspension arms, knuckles, links, bushings, and other suspension, steering and brake components. Hardware products


include threaded bolts, auto body and home fasteners, automotive and home electrical wiring components, and other hardware assortments and merchandise. Conflict Minerals are necessary to the functionality of certain of the Company’s products that the Company contracted to manufacture and for which the manufacture was completed during calendar year 2013 (the “Covered Products”). The Covered Products includes products from each of the four Product Groups. A list of the Covered Products is set forth on Appendix A to this Report.

Supply Chain Risk Management

The Company has identified certain supply chain risk categories which include disruptions, delays, systems, forecast, intellectual property, procurement, receivables, inventory and capacity. There is no simple solution to managing supply chain risk. The implementation of one strategy intended to mitigate a particular risk (e.g. purchase all product from one supplier to improve efficiencies) may cause the supply chain to face another risk (e.g. purchasing all product from one supplier increases the risk of disruptions and delays from events occurring near the supplier’s location). The Company minimizes its supply chain risk through the adoption of contingency planning and having a resilient and agile supply chain.

Due Diligence Measures Performed by the Company

The Company conducted a good faith reasonable country of origin inquiry with respect to the Conflict Minerals included in the Covered Products. This good faith inquiry was reasonably designed to determine whether any of the Conflict Minerals included in the Covered Products originated in the Covered Countries or were from recycled or scrap sources. The Company also performed due diligence with respect to the source and chain of custody of the Conflict Minerals included in the Covered Products. The Company’s due diligence measures were designed to conform to the framework in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas: Second Edition, including the related supplements on gold, tin, tantalum, and tungsten (the “OECD Guidance”).

Our Conflict Minerals project team is headed by our Vice President of Purchasing and includes members from our supply chain, engineering, quality, finance and legal departments. The team meets on a quarterly basis to discuss the due diligence process and progress. The Company’s supply chain with respect to the Covered Products is complex and there are many parties in the supply chain between the manufacturer of the Covered Products and the original source of the Conflict Minerals. As a contract manufacturer, we do not purchase Conflict Minerals directly from mines, smelters or refiners. Rather, we rely on the manufacturers to acquire the raw materials necessary for the Covered Products. The Company must therefore rely on its supply chain to provide information regarding the origin of the Conflict Minerals that are included in the Covered Products. Moreover, the Company believes that the smelters and refiners of the Conflict Minerals are best situated to identify the sources of Conflict Minerals, and therefore our due diligence process includes steps to identify the applicable smelters and refiners of Conflict Minerals in the Company’s Covered Products supply chain.

We began the due diligence process by first creating a list of products that we contract to manufacture which contained Conflict Minerals. We then identified the names of vendors from


whom we contracted to manufacture such products. Once identified, we sent each vendor a Conflict Minerals reporting template (described below) and a letter with instructions on how to complete the reporting template. We have adopted the Electronic Industry Citizenship Coalition (EICC) Conflict Minerals Due Diligence Reporting Template (the “Template”) as a standard questionnaire for conducting inquiries into our supplier’s sources of metals. This Template was created by the EICC and the Global e-Sustainability Initiative (GeSI) as a common means for the collection of sourcing information related to Conflict Minerals.

In completing the Template, each vendor was asked, among other questions, whether the products or components they supplied to us or manufactured for us contained Conflict Minerals; the origin of such Conflict Minerals; to identify the sources of Conflict Minerals from their lower tier level suppliers; and to determine the smelter or mine origin. Suppliers and manufacturers were asked to return a copy of the Template once completed. Upon return of the Template, the Conflict Minerals project team reviewed the contents of the response. If information on a Template returned from a vendor appeared to be incomplete, incorrect, or not trustworthy, our purchasing team would return the Template to the supplier by email with a request to complete or correct the questionable information. All returned Templates are stored in our supply chain Conflict Minerals records database to which all project team members have access. We maintain our supply chain Conflict Minerals records in a database developed by us specifically for this purpose.

If a vendor indicates that it is not willing to abide by the Company Policy or if the Company determines that a supplier is not sourcing Conflict Minerals in accordance with the Company Policy, the Company will take steps to replace that vendor as a source for Covered Products at the earliest practicable time.

As a contract manufacturer, we are a downstream purchaser of Conflict Minerals. As a result, our due diligence process can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the conflict minerals necessary to the function of the Covered Products. Our process relies on data obtained directly from our vendors who seek similar information within their supply chain to identify the original sources of the necessary Conflict Minerals. Such sources of information may yield inaccurate or incomplete information.

Based on the information that was provided by the Company’s vendors and otherwise obtained through the due diligence process, the Company believes that, to the extent reasonably determinable by the Company, the facilities that were used to process the Conflict Minerals contained in the Covered Products included the smelters and refiners listed on Appendix B to this report.

Based on the information obtained pursuant to the due diligence process, the Company does not have sufficient information with respect to the Covered Products to determine the country of origin of the Conflict Minerals in the Covered Products. The Company’s efforts to determine the mine or location of origin of the Conflict Minerals in the Covered Products consisted of the due diligence measures described in this Report. During the next compliance period, the Company intends to continue to engage, directly or through its supply chain, with the smelters and refiners set forth on Appendix B in order to identify the country of origin and mine or location of origin of the Conflict Minerals in the Covered Products.


The Company expects to take the following steps, among others, to improve its due diligence measures and to further mitigate the risk that the necessary Conflict Minerals contained in the Company’s products finance or benefit armed groups in the Covered Countries: (i) the Company will continue to engage with vendors, smelters and refiners in its supply chain to obtain current, accurate and complete information about the supply chain; (ii) the Company will again request information and supporting data from each vendor who provides the Company with Covered Products by utilizing the Template; and will pursue a fully and accurately completed Template; (iii) the Company is implementing contractual provisions in agreements with its suppliers or manufacturers that require the supplier or manufacturer to abide by the terms of the Company’s Conflict Mineral Policy; and (iv) the Company encourages its vendors to have only verifiably “conflict free” sources.


APPENDIX A

COVERED PRODUCTS

 

CV JOINT BOOTS
WHEEL CAPS
EXHAUST MANIFOLDS
HARMONIC BALANCERS
ENGINE ACCESSORY PULLEYS
RADIATOR FAN ASSEMBLIES
FAN PULLEY BRACKETS
INTAKE MANIFOLDS & GASKETS
AC BYPASS
FUEL TANKS
AXLE SHAFTS
4WD COMPONENTS
FUEL PUMPS
CLUTCH COMPONENTS
FUEL TANK LEVEL SENSORS
OIL PANS
TIMING COVERS
AIRBAG CLOCKSPRINGS
FUEL FILLER NECKS
WINDOW LIFT MOTORS
SUSPENSION COMPRESSORS
AUTOMOTIVE LIGHTING
AIR CLEANER ASSEMBLIES
WINDOW REGULATORS
AIR INTAKE HOSES
AIR DOOR ACTUATORS
DOOR LOCK ACTUATORS
CONTROL ARMS
HANDLES - DOOR & WINDOW
WIPER ARMS & MOTORS
MIRROR ASSEMBLIES
CAMSHAFT SYNCHRONIZERS
FLUID RESERVOIRS
FAN CLUTCHES
SHIFT SOLENOIDS
BACKUP SENSORS
STEERING SHAFTS
A.I.R. PUMPS & VALVES
MIRROR GLASS
WIRING ACCESSORIES
FUEL LINES
CLUTCH LINES
OIL COOLER LINES
TRANSMISSION LINES
HEATER HOSE ASSEMBLIES
EGR TUBES
DIFFERENTIAL COVERS
CONNECTORS & SWITCHES

ELECTRICAL & ELECTRICAL

TOOLS

AUTOMATIC BELT TENSIONERS
TIMING BELT ADJUSTERS
TORSION BARS
SHACKLES
RELEASE CABLES
PRIMARY WIRE
BRASS FITTINGS
NEW MASTER CYLINDER
ABS SENSORS
BLOWER MOTOR RESISTORS
STEERING KNUCKLES
HUB BEARINGS
SWAY BARS/BRACKETS
LEAF SPRINGS
TRANSMISSION PANS
WHEEL HUBS
INTEGRATED EXHAUST MANIFOLDS
PIGTAILS & SOCKETS
IDLER PULLEYS
TPMS SENSORS
CHASISS PARTS
INSTRUMENT CLUSTERS
WATER OUTLETS
BODY MOUNTS
BRAKE DUST SHIELDS
BLEND DOORS
SEAT HEATERS
ACC PEDAL SENSORS
FUEL AND EMISSIONS

VARIABLE VALVE TIMEING &

CAM PHASERS

SWITCHES
HARD TO FIND HARD PARTS
HAZARD SWITCHES
WIPER PULSE BOARDS (DISC.)
VALVE COVERS
DRIVE TRAIN
LIGHTS
VEHICLE SPEED SENSORS
WATER PUMP HOUSINGS
SLIDING DOOR MOTORS
DOOR HINGE REPAIR
TAILGATE PARTS & COMPONENTS
VENT WINDOW MOTORS
EXHAUST COMPONENTS
TRUNK AND LIFTGATE MOTORS
TRUNK AND LIFTGATE MOTORS
POWER STEERING COMPONENTS
THROTTLE BODY COMPONENTS
TRANSFER CASE CONTROL MODULES
COOLERS
CLIMATE CONTROL
MULTIFUNCTION SWITCHES
POWER WINDOW SWITCH MODULES
IGNITION SWITCHES
EMISSION CONTROL COMPONENTS
TOTALLY INTEGRATED POWER MODULES
MASS AIR FLOW SENSORS
RADIATOR FAN ASSEMBLIES
ELECTRICAL TERMINALS
ABS MODULES
ACTIVE SUSPENSION COMPONENTS
INTERIOR AND EXTERIOR BODY PARTS & FASTENERS
TRANSPONDER KEYS
MAINTENANCE FASTENERS
QUICK CONNECTORS
THREADED FASTENERS
CHROME WHEEL HARDWARE
EXPANSION PLUGS
OIL FILTER CAPS
OIL DRAIN PLUGS & GASKETS
SPINDLE NUTS
VACUUM CONNECTORS
WHEEL HARDWARE
VALUE PACKS AUTO
ASSORTMENTS
AROUND THE HOUSE
PICTURE HANGING
ANCHORS
WOOD SCREWS
SCREWS/BOLTS/NUTS
SHEET METAL SCREWS
NAILS
VALUE PACKS HOME
HARDWARE
GARAGE ORGANIZATION
CHAIN
HOME ORGANIZATION PRODUCTS
AUTO ORGANIZATION PRODUCTS
AUTOMOTIVE VENTS
FLOORING & FLOOR CARE
HOUSEHOLD TOOLS
BRAKE HYDRAULIC KIT
CLUTCH HYDRAULIC KIT
BRAKE HARDWARE
BRAKE CABLES
BRAKE HOSE
RADIOS
WHEEL CYLINDER
CLUTCH MASTER
CLUTCH SLAVE
IMPACT SENSORS
MAGNETIC CAM AND CRANKSHAFT SENSOR
BODY CONTROL MODULES
TRANSMISSION PARTS
BRAKES
STEERING AND SUSPENSION AUTO
EXHAUST AND INLET
CV JOINT BOOTS
WHEELS
PEDAL PADS & COMPONENTS
KEYLESS REMOTE CASES
HYBRID BATTERIES
 


APPENDIX B

SMELTERS AND REFINERS

 

BANKA TIN
CHINA MINMETALS

HUICHANG JINSHUNDA

TIN CO. LTD

MALAYSIA SMELTING CORP
METALLO CHIMIQUE

MINERAÇÃO TABOCA

S.A.

MINGSHIDA TIN SOLDERING

MATERIAL CO., LTD.

MINSUR
OMSA
PT BANGKA PUTRA KARYA
PT BUKIT TIMAH
PT KOBA TIN

PT STANINDO INTI

PERKASA

PT TIMAH

SHANDONG ZHAOYUAN

GOLD ARGENTINE

REFINING COMPANY

LIMITED

SHAOXING CITY SHENFA METAL FACTORY

THAILAND SMELTING

AND REFINING CO. LTD.

YUNNAN TIN COMPANY LIMITED
YUN NAN TIN CO. LTD
YUNTINIC RESOURCES INC.
YUNNAN CHENGFENG NON-FERROUS METALS CO LTD
HERAEUS HONG KONG
HERAEUS LTD HONG KONG
MITSUBISHI MATERIALS CORPORATION
THAILAND SMELTING AND REFINING CO. LTD.
THAISARCO

MITSUI MINING &

SMELTING

TANAKA

TANAKA KIKINNZOKU

KOGYO K.K.

PT REFINED BANKA TIN
CHINA MINMETALS
H.C. STARCK GMBH
CV DUTA PUTRA BANGKA
CV UNITED SMELTING

GLOBAL TUNGSTEN &

POWDERS CORP

RFH
PT TIMAH NUSANTARA

JIANGXI TUNGSTEN

INDUSTRY GROUP CO LTD

YOKOHAMA METAL CO

LTD

NIHON MATERIAL CO.

LTD

CHUGAI MINING
GANNON & SCOTT
TORECOM
PT SARIWIGUNA BINASENTOSA
DAEJIN INDUS CO. LTD

MATSUDA SANGYO CO.

LTD

DAERYONGENC
F&X ELECTRO-MATERIALS LIMITED
DO SUNG CORPORATION
TAKI CHEMICALS
HWASUNG CJ CO. LTD
TELEX
KOREA METAL
HC STARCK
CARIDAD

PT SUMBER JAYA

INDAH

JOHNSON MATTHEY INC
PT TAMBANG TIMAH

JIANGXI COPPER

COMPANY LIMITED

EM VINTO
PLANSEE
NINGXIA

AIDA CHEMICAL INDUSTRIES

CO. LTD.

GEJIU ZI-LI

SOLIKAMSK METAL

WORKS

GEIJU NON-FERROUS

METAL PROCESSING CO. LTD.

KEMET BLUE POWDER
GOLD BELL GROUP
CHONGYI ZHANGYUAN TUNGSTEN CO LTD
LIUZHOU CHINA TIN

ZHUZHOU CEMENTED

CARBIDE

SHANDONG GOLD

MINING (LAIZHOU)

ATI TUNGSTEN MATERIALS
SHANDONG ZHAOJIN GOLD & SILVER REFINERY CO. LTD
CNMC (GUANGXI) PGMA CO. LTD.
DOWA METALS & MINING CO. LTD
ZHONGJIN GOLD CORPORATION LIMITED
PT YINCHENDO MINING INDUSTRY

ALLGEMEINE GOLD- &

SILBERSCHEIDEANSTALT

PT BANGKA TIN INDUSTRY
CV JUSTINDO
CV MAKMUR JAYA
NOVOSIBIRSK INTEGRATED TIN WORKS
CV NURJANAH
COOKSON
CV SERUMPUN SEBALAI
DUOLUOSHAN SAPPHIRE RARE METAL CO. LTD
ARGOR-HERAEUS SA
JIUJIANG TANBRE

PT ALAM LESTARI

KENCANA

PT ARTHA CIPTA

LANGGENG

CONGHUA TANTALUM

AND NIOBIUM SMELTRY

PT BABEL SURYA ALAM

LESTARI

ASAKA RIKEN CO LTD
ULBA

PT BANGKA TIMAH

UTAMA SEJAHTERA

EXOTECH INC.
XSTRATA
CABOT CORPORATION
AGR MATTHEY
HI-TEMP
CHAOZHOU XIANGLU TUNGSTEN INDUSTRY CO LTD
PT EUNINDO USAHA MANDIRI

JIANGXI RARE EARTH &

RARE METALS TUNGSTEN GROUP CORP

PT FANG DI MULTINDO

XIAMEN TUNGSTEN CO

LTD

PT HP METALS INDONESIA

GANZHOU GRAND SEA

W & MO GROUP CO

LTD

A.L.M.T. CORP.

PT MITRA STANIA

PRIMA

KOJIMA CHEMICALS

CO. LTD

ASAHI PRETEC CORP

PT BELITUNG INDUSTRI

SEJAHTERA

PT BILLITIN MAKMUR

LESTARI