Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Ralph Lauren Corporation (the “Company”) designs, markets, and distributes premium lifestyle products including apparel, accessories, home furnishings and other licensed product categories. The Company does not directly manufacture products but rather contracts for the manufacture of products. This disclosure relates to the following product categories (the “Covered Products”): apparel, accessories, and home furnishings. The Covered Products include products: (a) that were manufactured by certain third parties that affixed the Company’s brand, marks, logo or label to a generic product; and (b) for which we exerted sufficient influence over the manufacture of the products such that we could be considered to have contracted for their manufacture. The Covered Products do not include licensed product categories.
Unless the context indicates otherwise, the terms “Company,” “we,” “us” and “our” refer to Ralph Lauren Corporation and its consolidated subsidiaries.
Conflict Minerals Disclosure
This Specialized Disclosure Form (“Form SD”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended (collectively with the Form SD, the “Conflict Minerals Rule”), for the period from January 1, 2014 to December 31, 2014 (the “Reporting Period”). We contract to manufacture certain products in which columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin and tungsten (collectively, the “3TGs”), may be necessary to the functionality or production of those products.
We are opposed to human rights abuses such as those occurring in the Democratic Republic of the Congo or an adjoining country (collectively the “Covered Countries”) and are committed to the principles of ethical business practice, including the responsible sourcing of 3TGs. We expect that our suppliers share this commitment and require that they cooperate with us in the compliance of the Conflict Minerals Rule.
We have conducted a review to determine whether our products contain any of the 3TGs. We determined that during the Reporting Period, we contracted to manufacture certain products that contained one or more 3TGs which were necessary to the functionality or production of those products. As a result of this determination, we conducted a reasonable country of origin inquiry (“RCOI”) to ascertain whether any of the 3TGs contained in our products originated in the Covered Countries. Based on our RCOI, we are unable to determine whether any of the 3TGs used in one or more of our products originated in, or were sourced from, the Covered Countries or that the 3TGs came from recycled or scrap sources. We have concluded that the status of our products is “DRC conflict undeterminable.”
Item 1.02 Conflict Minerals Report
A copy of the Company’s Conflict Mineral Report is provided as Exhibit 1.01 to this Form SD, and is publicly available at http://investor.ralphlauren.com.
Section 2 – Exhibits
Item 2.01 Exhibits
Exhibit 1.01 – Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form SD.