Manitowoc : Specialized Disclosure Report

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

Specialized Disclosure Report

The Manitowoc Company, Inc.

(Exact name of registrant as specified in its charter)

Wisconsin	1-11978	39-0448110
(State or other jurisdiction	(Commission File	(I.R.S. Employer
of incorporation or organization)	Number)	Identification No.)

11270 West Park Place, Suite 1000, Milwaukee, Wisconsin 53224

(Address of principal executive offices) (Zip Code)

Thomas L. Doerr, Jr.

Senior Vice President, General Counsel and Secretary

[phone]

(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:

1. R ule 1 3p-1 under the S ecurit ies E x c han ge A ct ( 17 C FR 24 0 . 1 3 p - 1 ) for the reporting peri od fro m January 1 to December 3 1 , 2018.

Section 1 - Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

Conflict Minerals Disclosure

A copy of The Manitowoc Company, Inc.'s (the "Company") Conflict Minerals Report for the reporting period from January 1, 2018 to December 31, 2018, is provided as Exhibit 1.01 hereto and is publicly available on the Company's website (www.manitowoc.com) under Investor Relations-Corporate Governance- Governance Documents-Additional Resources (ir.manitowoc.com/investor-relations/corporate-governance/governance-documents/default.aspx).

Item 1.02

Exhibit

See Item 2.01 of this Form.

Section 2 - Exhibits

Item 2.01

Exhibits

Exhibit 1.01 - Conflict Minerals Report of The Manitowoc Company, Inc., as required by Items 1.01 and 1.02 of this Form.

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.

THE MANITOWOC COMPANY, INC.(Registrant)

By:	/s/ Thomas L. Doerr, Jr	May 22, 2019
	Thomas L. Doerr, Jr.	(Date)
	Senior Vice President, General Counsel and Secretary

Exhibit 1.01

The Manitowoc Company, Inc.

Conflict Minerals Report

For the Year Ended December 31, 2018

Part I.

Introduction

This is the Conflict Minerals Report (the "Report") of The Manitowoc Company, Inc. (the "Company," "we," "us" or "our") for calendar year 2018 in accordance with Rule 13p-1 under the Securities and Exchange Act of 1934 ("the Rule"). This Report discusses the Company's efforts to determine whether any of the products we manufacture or contract to be manufactured contain columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, which are limited to tantalum, tin, and tungsten (collectively, "3TGs"), that are necessary to the functionality or production of such products that may have originated in the Democratic Republic of the Congo (the "DRC") or an adjoining country (collectively, the "Covered Countries") or are from recycled or scrap sources.

Part II. Company and Product Overview

The Company is one of the world's leading providers of engineered lifting solutions. The Company designs, manufactures, markets, sells and supports one of the most comprehensive product lines of mobile telescopic cranes, tower cranes, lattice-boom crawler cranes and boom trucks (collectively referred to herein as "Products"). The Company also supports customers globally with financing and leasing options and provides aftermarket parts and services to enable our customers to manage their fleets more effectively and deliver best in class total cost of ownership.

Our Conflict Minerals Steering Committee ("Committee") conducted an analysis of our supply chain (the "applicability assessment") and identified 3TGs that are necessary to the functionality or production of the Products we manufactured or contracted to be manufactured during calendar year 2018. Our Products generally contain (in varying degrees and amounts) some 3TGs necessary to their functionality or production.

Part III. Reasonable Country of Origin Inquiry ("RCOI")

We began our scoping process by identifying a list of our Products that may contain 3TG and then we extracted a list of suppliers who provide us with identified products. The supplier list with contact information and parts were then provided to our third-party service provider, Assent Compliance ("Assent"). Suppliers have the option of completing their CMRT (as defined below) on the product or company level. This supplier list was then uploaded to our third-party provider's software platform that allows us to store and manage supplier requests and documentation.

To ensure that our suppliers understood our expectations regarding the sourcing of 3TGs, we provided training through webinars, videos, documentation and one- on-one discussions. We continued to put a strong emphasis on supplier education and training via Assent University's Learning Management System: Conflict Minerals course.

Utilizing the Conflict Minerals Reporting Template (the "CMRT"), version 5.10 or higher, developed by the Responsible Business Alliance and the Global e- Sustainability Initiative, the suppliers were surveyed on their sourcing of the 3TGs. The CMRT includes questions regarding a direct supplier's conflict minerals policy, its due diligence process, and information about its supply chain, such as the names and locations of smelters and refiners as well as the origin of 3TGs used by those facilities. All communications were tracked and monitored in our third-party provider's software platform. Non-responsive suppliers were contacted a minimum of three times by our third-party service provider.

The supplier responses were received and reviewed for completeness and consistency. A ll suppliers who submitted CMRTs that were flagged as "invalid" were contacted at least twice to review submissions. These communications were monitored and tracked in our third-party service provider's system for future reporting and transparency. As of May 1 , 2019 , we had received responses from 77 % of the 423 suppliers surveyed .

Based on the RCOI, we determined that we may have some suppliers who sourced 3TGs from the Covered Countries. Therefore, in an effort to identify mines with the greatest possible specificity, we conducted due diligence on our supplier base, as described below.

Part IV.

Due Diligence

In accordance with Securities and Exchange Commission ("SEC") rules, the Company undertook due diligence efforts to determine whether the 3TGs in the Products we manufacture, or contract to manufacture, that are necessary to the functionality or production of our Products originated in the Covered Countries or are from recycled or scrap sources. The Company designed due diligence measures to conform, in all material respects, with the internationally recognized due diligence framework set forth in the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition, and related supplements for each of the Conflict Minerals (the "OECD Guidance").

Our due diligence process for 2018 included the steps described below:

Step 1: Establish strong Company management systems

We are committed to the responsible sourcing of our Products and we expect the same from our suppliers, including ensuring that the products or components supplied to us do not directly or indirectly finance or benefit armed groups in the Covered Countries. Our suppliers are required to support our efforts to comply with the Rule. We have developed a Conflict Minerals Policy, which is available on our website (www.manitowoc.com) under Investor Relations-CorporateGovernance-GovernanceDocuments-Additional Resources. In addition, our standard supplier terms and conditions address our expectations related to Products containing 3TGs supplied to us.

The Company also maintains a grievance mechanism whereby employees and suppliers can report violations of the Company's policies, including with respect to conflict minerals. In addition, our employees may anonymously report suspected violations using Manitowoc's Corporate Governance/Whistleblower Hotline, available 24 hours a day, seven days a week. This hotline is staffed by non-Manitowoc personnel, who share any information reported with our General Counsel and our Audit Committee.

The Committee, which includes representatives from supply chain management, procurement and legal reports to the Company's senior leadership, oversees supplier due diligence regarding Conflict Minerals. The Committee is also responsible for educating procurement and supply chain employees regarding our Conflict Minerals expectations and overseeing the preparation of this Report with assistance from consultants and advisors as needed.

The Company retained information regarding our due diligence efforts for 2018 in accordance with our existing record retention policies and procedures.

Step 2: Identify and assess risk in the supply chain

Our due diligence efforts were based on a survey process in which we requested certain information from selected suppliers who we believed may be providing parts or components containing 3TGs by using the CMRT, as previously discussed. More specifically, the Committee oversaw the following:

• A supply chain survey of suppliers identified during the "applicability assessment" and ROCI who the Company believed represented the highest risk of supplying parts or components that may contain 3TGs