Exhibit 1.01
Conflict Minerals Report
The Greenbrier
Companies, Inc. (the Company, Greenbrier, we, us, or our) has included this Conflict Minerals Report as an exhibit to its Form SD as required by Rule
13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD (collectively, the Conflict Minerals Rule). Greenbrier is one of the leading designers, manufacturers and marketers of
railroad freight car equipment in North America and Europe, a manufacturer and marketer of marine barges in North America (until May 15, 2023), and a leading provider of wheel services, railcar refurbishment and parts, repair, leasing and other
services to the railroad and related transportation industries in North America.
We support ending the violence and human rights abuses taking place in
the Democratic Republic of the Congo (the DRC) and its adjoining countries (the Covered Countries). We are committed to ensuring that any conflict minerals necessary to the functionality or production of our products are
sourced from sources that do not fund armed conflict in the Covered Countries.
Conflict Minerals Policy
We have adopted and posted on our public internet site a company policy for the supply chain of conflict minerals (the Conflict Minerals Policy).
As used herein and in the Conflict Minerals Policy, conflict minerals are gold, columbite-tantalite (coltan), cassiterite and wolframite and their derivatives (currently limited to tantalum, tin and tungsten), and any other mineral or
its derivatives determined by the Secretary of State to be financing conflict in the Covered Countries without regard to the location of origin of the minerals or derivative metals. Our Conflict Minerals Policy includes, but is not limited to, our
expectations that our suppliers:
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refrain from using materials that fund armed conflict and human rights atrocities in the Covered Countries in the
products they sell to Greenbrier, |
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complete a conflict minerals questionnaire in a timely manner, and |
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if requested, provide supporting documentation. |
The Conflict Minerals Policy indicates that, in the event that we determine that a suppliers efforts to comply with the Conflict Minerals Policy have
been insufficient or the supplier fails to cooperate in developing and implementing reasonable steps to comply, we reserve the right to take appropriate actions necessary up to and including discontinuing the business relationship with the supplier.
The Conflict Minerals Policy has been communicated internally to relevant personnel and posted on our website.
Due Diligence Program
We have adopted a due diligence
process to be applied to materials or components included in our products which our reasonable country of origin inquiry (RCOI) identifies may have originated in the Covered Countries. The process follows the applicable framework set
forth in the Organization for Economic Co-operation and Developments (the OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, as
supplemented by the Supplement on Tin, Tantalum and Tungsten and the Supplement on Gold, Third Edition 2016 (collectively, the OECD Guidance), taking into account the facts and circumstances of our company, products and place in the
supply chain.
The OECD Guidance has established a five-step framework for due diligence as a basis for responsible global supply chain management of
minerals from conflict-affected and high-risk areas. This framework consists of the following elements:
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Establish strong company management systems (Step One); |
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Identify and assess risk in the supply chain (Step Two); |
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