California Transparency in Supply Chains Act Disclosure

Last Updated: October, 5 2020

LeapFrog (together with group of companies of VTech Holdings Ltd.) makes this disclosure pursuant to the California Transparency in Supply Chains Act of 2010, a law designed to increase the amount of information manufacturers and retailers make public regarding their efforts to address the issue of slavery and human trafficking in their supply chains.

At LeapFrog, we are committed to conducting our business in a lawful and ethical manner, and we expect the same from our suppliers. As part of this commitment, we have no tolerance for slavery or human trafficking in our supply chain.

LeapFrog has taken the following steps to eradicate slavery and human trafficking from its supply chain:

Verification. LeapFrog strives to establish and maintain close working relationships with its suppliers. LeapFrog does not rely upon third parties to verify its product supply chains in order to evaluate and address risks of slavery and human trafficking.

Supplier Audits. LeapFrog’s own factory in China is audited frequently by major U.S. retailers, partly for the purpose of establishing compliance with applicable laws, as well as their own corporate policies on employment and workplace standards. LeapFrog also has a program to audit its suppliers. Additionally, we know many of our suppliers have their own codes of conduct and auditing programs that assist them in complying with LeapFrog's requirements that they operate their factories in accordance with all applicable laws.

Certification. While LeapFrog does not require its suppliers to certify that materials incorporated into their products comply with the slavery and human trafficking laws of the countries where they are doing business, LeapFrog's standard purchasing agreement includes requirements that our suppliers comply with all applicable laws, including laws that govern slavery, human trafficking, and other exploitative labor practices.

Internal Accountability. All LeapFrog employees are required to comply with our written, company-wide ethical code, which promotes honest and ethical conduct, as well as legal and regulatory compliance. LeapFrog’s ethical code requires all employees to follow all applicable laws, including those prohibiting forced labor or trafficking.

Employee Training and Accountability. We provide training on human rights for our employees. Employees that interact with suppliers are expected to report any potentially unlawful or unethical conduct that comes to their attention, including the presence of slavery or human trafficking in LeapFrog’s supply chain. Under our Whistleblower Policy, any such report will be promptly and appropriately investigated.

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