ZAGG’s Statement on Slavery and Human Trafficking

The California Transparency in Supply Chains Act of 2010, effective January 1, 2012, requires large retailers and manufacturers doing business in the state of California, to be transparent about efforts undertake to eradicate slavery and human trafficking in their direct supply chains for tangible goods offered for sale.

ZAGG has a zero-tolerance policy for slavery and human trafficking and holds it manufacturers to the highest standard. ZAGG requires each of its manufacturers to agree to and execute its Manufacturer’s Code of Conduct, which requires its Manufacturers to comply with all applicable laws and regulations, to treat each employee with dignity and respect, to not discriminate, and to provide all employees with a safe and healthy workplace. Furthermore, each Manufacturer agrees that its factory may be inspected at any time and that any noncompliance will result in an immediate breach of the Supply Agreement.

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 on an annual basis to sign an agreement stating that it will not use subcontractors or independent contractors for the manufacturing of ZAGG products or components thereof without ZAGG’s express written consent. If ZAGG provides such written consent for use of subcontractors or independent contractors, ZAGG requires its manufacturers to verify that the subcontractors and independent contractors agree to ZAGG’s Manufacture’s Code of Conduct.

Audits

ZAGG has implemented a process to perform internal unannounced audits annually in addition to internal announced audits of its manufacturers to evaluate compliance with ZAGG’s standards for human trafficking and slavery. In accordance with this process, each manufacturer is audited at least twice per year and at least one audit is unannounced.

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.