MasterCraft Boat Holdings, Inc.
Conflict Minerals Report
For the Year Ended December 31, 2024
Company Overview
MasterCraft Boat Holdings, Inc. (the “Company”, “we” or “our”) is the parent entity of MasterCraft Boat Company, LLC and Crest Marine, LLC. We are a leading designer, manufacturer, and marketer of recreational powerboats. Our boats are used for water skiing, wakeboarding and wake surfing, as well as general recreational boating. As a leader in recreational marine, we strive to deliver the best on-water experience through innovative, high-quality products with a relentless focus on the consumer.
Summary
Based on the Company’s reasonable country of origin inquiry (“RCOI”) and the procedures described in this Form SD, the Company has determined that, with respect to the majority of products subject to inquiry by Rule 13p1 for the period from January 1, 2024 to December 31, 2024 (the “Reporting Period”), the Company has no reason to believe these products contain Conflict Minerals (as defined in Rule 13p1) that may have originated in the Democratic Republic of Congo or an adjoining country (collectively, the “Covered Countries”).
With respect to a minority of products subject to inquiry by Rule 13p1 for the Reporting Period, there is reason to believe that Conflict Minerals contained in those certain products may have originated in the Covered Countries.
Reasonable Country of Origin Inquiry (RCOI)
For products manufactured or contracted to manufacture that were completed during the Reporting Period (the “Completed Products”), the Company evaluated those products to determine if Conflict Minerals may have been present and potentially necessary to the production or functionality of the Completed Products. Following this evaluation, the Company then engaged in a RCOI by identifying, through a risk-based approach, those suppliers that were likely to provide products containing Conflict Minerals during the year ended December 31, 2024. The Company then contacted each identified supplier to ascertain whether Conflict Minerals were used in the supplier’s products as provided to the Company. In aggregate, the Company reviewed over 330 supplier responses during the Reporting Period.
Supplier responses can be grouped into five main categories:
(1) |
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The supplier represented that its products did not contain Conflict Minerals from the Covered Countries. |
(2) |
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The supplier represented that it had not completed its own diligence about its products in order to be able to certify to the Company whether the supplier’s products contain Conflict Minerals from the Covered Countries. |
(3) |
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The supplier represented that it had completed its diligence but was unable to determine whether its products contain Conflict Minerals from the Covered Countries. |
(4) |
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The supplier represented that its products contained Conflict Minerals that did or may have originated in the Covered Countries. |
(5) |
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The supplier provided no response to the inquiry. |
The Company evaluated each response to provide a level of assurance as to the response’s validity. For nonresponsive suppliers, the Company conducted additional outreach (including mailings or telephone contact).