The U.S. Securities and Exchange Commission adopted regulations implementing section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act in August of 2012. The regulations require publicly traded companies to disclose their use of certain conflict minerals (tin, tantalum, tungsten and gold) that originate from conflict mines in the Democratic Republic of Congo (DRC) or adjoining countries.

LeapFrog is committed to identifying any conflict minerals contained in our products as a part of our social responsibility and in order to achieve compliance with conflict minerals regulations.

LeapFrog’s Activities

LeapFrog will work with suppliers to trace back mineral flows and ensure commitment to sustainable procurement. Starting in 2012 we will take into use the standardized EICC-GeSI Conflict Minerals Reporting Template to continue mapping and to monitor our suppliers’ commitment and activities.

We have incorporated the principles of this policy into our LeapFrog Supplier Requirements (LFSR) and we work with our suppliers to increase transparency in the supply chain. We aim to create awareness and build capacity within our supplier base through training and regular supplier meetings. We will communicate our policy to our suppliers and request them to set similar policies for their supply chain.

LeapFrog supports and will rely on industry initiatives, such as the Conflict Free Smelter Program (CFS), to determine if conflict minerals used in our products are contributing to conflict. LeapFrog supports in-region sourcing schemes (e.g. iTSCi), which are essential for the success of CFS, through industry initiatives and related partnerships.

LeapFrog supplier requirements

It is LeapFrog’s policy that our suppliers who manufacture components, parts, or products containing tin, tantalum, tungsten, and/or gold must work toward sourcing those materials from conflict free suppliers. We request that suppliers define, implement and communicate to sub-suppliers their own policy, outlining their commitment to responsible sourcing of these materials, legal compliance and measures for implementation. We also request that suppliers shall work with sub-suppliers to ensure traceability of these materials at least to smelter level by using the EICC-GeSI Minerals Reporting Template or other documents required by LeapFrog. LeapFrog may request further evidence of the supply chain down to mine level when necessary. Traceability data shall be maintained and recorded for 5 years and provided to LeapFrog upon request.

Suppliers are encouraged to support industry efforts to enhance traceability and responsible practices in global minerals supply chains.

Assessing and responding to the identified risks

LeapFrog collects material composition information for all our products which allows us to identify suppliers that use tin, tantalum, tungsten and/or gold in their products. Material composition data along with information gathered from suppliers (e.g. with the EICC-GeSI Conflict Minerals Reporting Template), industry initiatives (e.g. CFS), and other available sources is used to assess whether there are conflict minerals in our product.

If we identify a reasonable risk that a supplier is violating our commitments set forth in this policy, we request that they commit to and implement a corrective action plan within a reasonable timeline.

Conflict Minerals Report