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Form SD ENERPAC TOOL GROUP CORP

May 27, 2021 4:17 PM EDT

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
Form SD
Specialized Disclosure Report

_________________________________________________________________
ENERPAC TOOL GROUP CORP
(Exact name of Registrant as specified in its charter)
______________________________________________________________________________

Wisconsin1-1128839-0168610
(State or other jurisdiction of incorporation or organization)(Commission File Number)(I.R.S. Employer Identification No.)

N86 W12500 WESTBROOK CROSSING
MENOMONEE FALLS, WISCONSIN 53051


Mailing address: P.O. Box 3241, Milwaukee, Wisconsin 53201
(Address of principal executive offices) (Zip code)


Fabrizio Rasetti
Executive Vice President, General Counsel and Secretary
(262) 293-1500
(Name and telephone number, including area code,
of the person to contact in connection with this report.)








_____________________________________________________________________________________________
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:
[X] Rule 13p-1 under the Securities Exchange Act (17CFR 240.13p-1) for the reporting period from January 1 to December 31, 2020.



Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
A copy of Enerpac Tool Group Corp.’s Conflict Minerals Report for the calendar year ended December 31, 2020 is filed as Exhibit 1.01 hereto and is publicly available at www.enerpactoolgroup.com.

Item 1.02 Exhibits
Enerpac Tool Group Corp.’s Conflict Minerals Report for the calendar year ended December 31, 2020 is filed as Exhibit 1.01 hereto.

Section 2 - Exhibits
Item 2.01 Exhibits
Exhibit 1.01 - Conflict Minerals Report as required by Items 1.01 and 1.02 of 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 duly authorized undersigned.
ENERPAC TOOL GROUP CORP.
(Registrant)

By:  /s/ Fabrizio Rasetti
May 27, 2021
Fabrizio Rasetti(Date)
Executive Vice President, General Counsel and Secretary



Exhibit 1.01

ENERPAC TOOL GROUP CORP.
Conflict Minerals Report
For The Year Ended December 31, 2020
Introduction:
Enerpac Tool Group Corp. (“Company”, “Enerpac”, “we”, “our”, or “us”) is a premier industrial tools and services company serving a broad and diverse set of customers in more than 100 countries and more than a dozen end-markets, including industrial maintenance, repair and operations, energy, construction, power generation and mining. Our products include branded tools, cylinders, hydraulic torque wrenches and highly engineered heavy lifting technology solutions, and our service offerings include supplying highly trained technicians to provide maintenance and manpower services on oil and gas assets to meet customer-specific needs. We also rent certain of our products. Our manufacturing activities primarily consist of light assembly of components we source from a global network of suppliers, although we also have machining, stamping, injection molding and fabrication capabilities. For the calendar year ended December 31, 2020, the Company was organized in one reportable segment, Industrial Tools & Services.
Certain Enerpac products contain materials or components containing gold, tantalum, tin, and/or tungsten (collectively, "3TG"). Therefore, in accordance with Rule 13p-1 of the Securities Exchange Act of 1934 (the "Exchange Act"), we have investigated, and are reporting on, the origin of the 3TG used in our products to ascertain whether the 3TG originated from the Democratic Republic of Congo or adjoining countries ("Covered Countries").
Conflict Minerals Policy:
Enerpac is committed to ethical business practices and promoting the safety, health and well-being of the communities we impact. We are guided in our pursuit and implementation of these principles by our Code of Conduct and Conflict Minerals Policy, which are available in the Investors - Governance section of the Company’s website (www.enerpactoolgroup.com).
The Conflict Minerals Policy affirms our commitment to responsible sourcing practices for our components and raw materials. Consistent with the Conflict Minerals Policy, we direct our business to suppliers who can confirm their products are from conflict-free sources and eliminate non-conforming suppliers and products from our supply chain.
Supply Chain Due Diligence:
We conduct a country-of-origin inquiry and due diligence of our supply on an annual basis. We have designed our due diligence measures to be in conformity in all material respects with the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (2016) and related supplements for each of the Conflict Minerals (the “OECD Guidance”). Summarized below are the five-step framework set forth in the OECD Guidance and the corresponding due diligence measures we have undertaken.
Establish Company Management Systems:
We maintain a cross-functional 3TG compliance team that includes employees from our supply chain, trade compliance, legal, finance and operations functions. This team is responsible for administering our 3TG compliance program, including communicating updates to senior management and providing organizational guidance on the rules. Our compliance program includes supplier engagement and processes for reporting exceptions to our Conflict Minerals Policy. We also have included conflict minerals compliance clauses in purchase orders and supplier contracts to confirm our standards and enforce our requirements.
Identify and Assess Risk in the Supply Chain:
Our operations are several steps removed from the mining of minerals and we do not directly source minerals. As part of our diligence measures, we conduct a country-of-origin inquiry to determine whether any of the 3TG in our products originated in the Covered Countries. Because of the diversity of our products and the global nature of our supply chain, we rely on our suppliers to provide us with information about the source and content of components we purchase from them and incorporate into our products. Similarly, our direct suppliers also rely on information provided by their suppliers. This chain of information creates a level of uncertainty and risk related to the accuracy of the information we receive.
Our country-of-origin inquiry process and due diligence measures are conducted by a third-party provider engaged by us for this purpose. The third-party provider:
manages the supplier solicitation process that includes sending a survey to selected direct material suppliers (210 suppliers) using the Conflict Free Sourcing Initiative Conflict Minerals Reporting Template (“CMRT”),
aggregates CMRT responses for analysis and reporting,



evaluates responses from suppliers and reviews the results of due diligence to ensure the completeness and accuracy of the responses received from our supply chain,
identifies quality issues (e.g., incomplete CMRTs, inconsistent responses and red flags based on defined criteria),
assesses whether the processing facilities reported to us by our suppliers are included on the list of Conflict Free Sourcing Initiative-compliant processing facilities, and
provides additional documentation and verifications, as required.
We believe the inquiries and due diligence measures described above represent an appropriate and reasonable effort to determine the origins of the 3TG in our products. Most of the suppliers we evaluated provided comprehensive responses to the CMRT, although some only provided interim responses or incomplete information despite attempts to obtain comprehensive information.
Design and Implement a Strategy to Respond to Identified Risks:
We expect our suppliers to source minerals from responsible and Conflict Free Sourcing Initiative-compliant sources and believe in establishing and maintaining long-term relationships with compliant suppliers. If, as a result of our due diligence measures, we determine that a supplier is violating our Conflict Minerals Policy, we will either seek an alternate supplier or require a suitable corrective action plan. In limited cases, identifying alternate sources can be difficult and require lengthy implementation periods.
Carry Out Independent Third-Party Audit of Smelter/Refiner’s Due Diligence Practices:
We do not perform direct audits of 3TG smelters and refiners within our supply chain since we are a downstream consumer and several steps removed from smelters and refiners that provide minerals and ores.
Report on Supply Chain Due Diligence:
We are filing this report (and the related Form SD) with the SEC and are making it publicly available on the Investors - Governance section of our website at www.enerpactoolgroup.com.
Due Diligence Results:
The most frequently utilized smelters in our supply chain, as reported by our suppliers, are included in Schedule A to this Conflict Minerals Report. Our review of the most frequently utilized smelters generally did not identify any facilities considered to be at risk of violating our Conflict Minerals Policy, but it did identify ten suppliers whose supply chain includes a smelter or refiner in Covered Countries or are high-risk.
Due to still-incomplete information provided by those suppliers (including in response to our follow-up inquiries), we cannot definitively say whether the components or parts supplied to Enerpac from these ten suppliers contain 3TG from these smelters or refiners and are continuing to evaluate whether products supplied by those suppliers contain 3TG originating in the Covered Countries.
Ongoing Steps to Mitigate Risk:
We continue to evaluate our due diligence program to enhance the information available to us and better mitigate risks in our supply chain. We will continue to communicate the expectations to our suppliers that all products containing conflict minerals must be sourced from Responsible Minerals Assurance Process compliant smelters. Additionally, we will request that suppliers confirm that our products do not contain 3TG from non-compliant or high-risk smelters or that said smelters and refiners be removed from their supply chain. Where warranted, the supplier will be made aware that if it does not commit to removing a smelter or refiner, we will look for alternative sources for the product.
Independent Audit:
For the year ended December 31, 2020, pursuant to SEC rules and related guidance, an independent private sector audit of this report was not required.



Schedule A to
Conflict Minerals Report of
Enerpac Tool Group Corp.
For the Year Ended December 31, 2020

The following smelters and refiners were most frequently reported by our suppliers as being in their supply chains.
METAL SMELTER/ REFINER NAMEFACILITY LOCATION
GoldRoyal Canadian MintCanada
GoldSolar Applied Materials Technology Corp.Taiwan
GoldAngloGold Ashanti Corrego do Sitio MineracaoBrazil
GoldCCR Refinery - Glencore Canada CorporationCanada
GoldHeraeus Metals Hong Kong Ltd.China
GoldHeraeus Germany GmbH Co. KGGermany
GoldMaterionUnited States
GoldMetalor USA Refining CorporationUnited States
GoldPX Precinox S.A.Switzerland
GoldRand Refinery (Pty) Ltd.South Africa
GoldSEMPSA Joyeria Plateria S.A.Spain
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.China
GoldSumitomo Metal Mining Co., Ltd.Japan
GoldTanaka Kikinzoku Kogyo K.K.Japan
GoldTokuriki Honten Co., Ltd.Japan
GoldTorecomKorea, Republic Of
GoldUmicore S.A. Business Unit Precious Metals RefiningBelgium
GoldValcambi S.A.Switzerland
GoldWestern Australian Mint (T/a The Perth Mint)Australia
GoldYamakin Co., Ltd.Japan
GoldYokohama Metal Co., Ltd.Japan
GoldUmicore Precious Metals ThailandThailand
TantalumKEMET de MexicoMexico
TantalumTANIOBIS Co., Ltd.Thailand
TantalumTANIOBIS GmbHGermany
TantalumH.C. Starck Hermsdorf GmbHGermany
TantalumGlobal Advanced Metals BoyertownUnited States
TantalumExotech Inc.United States
TantalumF&X Electro-Materials Ltd.China
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.China
TantalumJiujiang Tanbre Co., Ltd.China
TantalumAMG Brasil - LSM BrasilBrazil
TantalumMetallurgical Products India Pvt., Ltd.India
TantalumMitsui Mining and Smelting Co., Ltd.Japan
TantalumQuantumCleanUnited States
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.China
TantalumSolikamsk Magnesium Works OAORussian Federation
TantalumTaki Chemical Co., Ltd.Japan
TantalumTelex MetalsUnited States
TantalumUlba Metallurgical Plant JSCKazakhstan
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.China



METAL SMELTER/ REFINER NAMEFACILITY LOCATION
TantalumD Block Metals, LLCUnited States
TantalumFIR Metals & Resource Ltd.China
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.China
TantalumXinXing HaoRong Electronic Material Co., Ltd.China
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.China
TantalumH.C. Starck Inc.United States
TantalumTANIOBIS Japan Co., Ltd.Japan
TantalumTANIOBIS Smelting GmbH & Co. KGGermany
TantalumGlobal Advanced Metals AizuJapan
TantalumResind Industria e Comercio Ltda.Brazil
TantalumJiangxi Tuohong New Raw MaterialChina
TinPT Timah Tbk MentokIndonesia
TinThaisarcoThailand
TinMalaysia Smelting Corporation (MSC)Malaysia
TinPT Mitra Stania PrimaIndonesia
TinPT Refined Bangka TinIndonesia
TinMetallo Belgium N.V.Belgium
TinMinsurPeru
TinGejiu Non-Ferrous Metal Processing Co., Ltd.China
TinJiangxi New Nanshan Technology Ltd.China
TinPT Timah Tbk KundurIndonesia
TinRui Da HungTaiwan
TinYunnan Tin Company LimitedChina
TinDowaJapan
TinEM VintoBolivia
TinGejiu Zili Mining And Metallurgy Co., Ltd.China
TinGejiu Kai Meng Industry and Trade LLCChina
TinSoft Metais Ltda.Brazil
TinMelt Metais e Ligas S.A.Brazil
TinO.M. Manufacturing Philippines, Inc.Philippines
TinMineracao Taboca S.A.Brazil
TinMitsubishi Materials CorporationJapan
TinO.M. Manufacturing (Thailand) Co., Ltd.Thailand
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.China
TinWhite Solder Metalurgia e Mineracao Ltda.Brazil
TungstenKennametal FallonUnited States
TungstenKennametal HuntsvilleUnited States
TungstenChongyi Zhangyuan Tungsten Co., Ltd.China
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.China
TungstenJapan New Metals Co., Ltd.Japan
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.China
TungstenXiamen Tungsten Co., Ltd.China
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.China
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.China
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.China
TungstenMalipo Haiyu Tungsten Co., Ltd.China
TungstenXiamen Tungsten (H.C.) Co., Ltd.China
TungstenJiangxi Gan Bei Tungsten Co., Ltd.China



METALSMELTER/ REFINER NAMEFACILITY LOCATION
TungstenH.C. Starck Tungsten GmbHGermany
TungstenMasan High-Tech MaterialsVietnam
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.China
TungstenNiagara Refining LLCUnited States
TungstenGanzhou Haichuang Tungsten Co., Ltd.China
TungstenHydrometallurg, JSCRussian Federation
TungstenUnecha Refractory metals plantRussian Federation
TungstenPhilippine Chuangxin Industrial Co., Inc.Philippines
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.China
TungstenACL Metais EireliBrazil
TungstenWoltech Korea Co., Ltd.Korea, Republic Of
TungstenMoliren Ltd.Russian Federation




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