Verification
ZAGG engages in internal verification activities annually to identify, assess and manage the risks of human trafficking in its product supply chain. ZAGG requires each manufacturer to sign an agreement stating that it will only use subcontractors or independent contractors who are compliant with and agree to ZAGG’s Code of Conduct.
Audits
ZAGG performs internal announced audits of its manufacturers to evaluate compliance with ZAGG’s standards for human trafficking and slavery on an annual basis. In addition, ZAGG has implemented a process to perform internal unannounced audits and plans to do so in the near future.
Certifications
ZAGG requires its manufacturers to certify it complies with the labor laws of the countries in which they do business. A manufacturer is in breach of ZAGG’s Supply Agreement if it fails to acquiesce.
Internal Accountability
ZAGG has internal procedures for determining whether employees or contractors are complying with company standards regarding slavery and human trafficking. ZAGG’s Legal Department conducts an annual training in which employees are trained on human trafficking and slavery awareness within our manufacturers. ZAGG’s Operations and Product teams are required to attend such trainings as those departments are primarily responsible for monitoring compliance. Furthermore, ZAGG requires each employee to be familiar with ZAGG’s Manufacturer’s Code of Conduct.
Training
As stated previously, ZAGG has implemented a training program in which ZAGG employees are trained annually to have the ability to identify key indicators that are likely to exist with human trafficking and/or slavery. ZAGG has a zero-tolerance policy for any kind of human trafficking and slavery and explicitly communicates this policy to all of its manufacturers.
Conflict Minerals Policy
1. Purpose and Commitment
Zagg International is committed to responsible sourcing of minerals and to ensuring that our procurement practices do not contribute to conflict, human rights abuses, or other adverse impacts. This policy establishes the framework by which we identify, assess, and manage risks associated with tin, tantalum, tungsten, and gold (3TG) sourced from conflict-affected and high-risk areas (CAHRAs).
This policy aligns with the OECD Due Diligence Guidance, a globally recognized, government-endorsed framework for minerals sourcing. The Guidance provides step-by-step recommendations for responsible supply chains of all minerals to help companies respect human rights and avoid contributing to conflict. oecd.org
2. Scope
This policy applies to:
- All business units and employees of Zagg International
- All direct suppliers and their upstream supply chain partners
- All products containing or potentially containing 3TG minerals
The policy is applicable regardless of geographic location and in accordance with the international conflict minerals rules and standards (e.g., Dodd-Frank 1502, EU 2017/821, Swiss Ordinance on Due Diligence and Transparency), which companies are expected to follow.
3. Definitions
Conflict Minerals
Tin, tantalum, tungsten, and gold sourced from conflict-affected and high-risk areas, where extraction and trade may be linked to human rights abuses or armed groups. The OECD Guidance identifies these minerals as high-risk and provides due diligence expectations for them.
CAHRAs (Conflict-Affected and High-Risk Areas)
Areas identified as having potential risks such as armed conflict, forced labour, human rights violations, or weak governance. Regulatory bodies maintain lists of CAHRAs to support risk identification.
4. Our Commitments
Zagg International commits to the following:
4.1 Responsible Sourcing
We will not knowingly procure minerals that contribute to conflict, human rights abuses, or the financing of armed groups. This reflects industry expectations that companies should avoid contributing to such harms through sourcing practices.
4.2 Continuous Improvement
We view due diligence as a continuous process of improvement, consistent with current industry trends emphasising ongoing risk assessment and transparency.
4.3 Support for Legal and International Requirements
We comply with all applicable conflict minerals regulations that reference or incorporate the OECD Guidance, including U.S., EU, and Swiss requirements.
5. Due Diligence Framework
We adopt the OECD’s Five-Step Due Diligence Framework, recognized globally as the standard approach for responsible mineral sourcing. OECD Due Diligence Guidance
Step 1 — Establish a Management System Approach
By:
- Adopting and publishing this policy
- Building internal capacity to implement due diligence
- Implementing supply chain controls and traceability
- Establishing a grievance mechanism open to suppliers and external stakeholders
Step 2 — Identify, Assess & Prioritise Supply Chain Risks
By:
- Collecting information on mineral sources, smelters, and refiners
- Screening for red flags
- Conducting enhanced due diligence where required
- Prioritising risks based on OECD Annex II criteria
Step 3 — Manage and Mitigate Identified Risks
By:
- Reporting findings to senior management
- Taking appropriate action to influence and support suppliers to mitigate risks
- Disengaging only from suppliers involved in the most severe abuses
Step 4 — Support Independent Third-Party Audits
Where applicable, encouraging suppliers, particularly smelters and refiners, to participate in independent third-party audits aligned with OECD expectations.
Step 5 — Report Annually on Our Due Diligence Efforts
By:
- Including in our annual report supply chain due diligence activities
- Describing risks identified and actions taken
- Reporting progress against continuous-improvement goals
6. Supplier Expectations
All suppliers must:
- Acknowledge and adhere to this Conflict Minerals Policy
- Conduct due diligence aligned with the OECD Guidance
- Provide accurate and timely data on their supply chains
- Implement their own traceability and grievance systems
- Cooperate with assessments, corrective actions, and audits. This expectation is consistent with industry practice requiring suppliers to familiarize themselves with conflict minerals laws and the OECD Guidance.
7. Review and Updates
This policy will be reviewed annually to ensure alignment with evolving laws, standards, and industry best practices, including discussions and updates emerging from OECD.