Conflict Minerals Policy


In response to concerns regarding "conflict minerals" emanating from mining operations in the Democratic Republic of the Congo ("DRC") and nine adjoining countries (collectively with the DRC, the "Conflict Region"), the United States Congress enacted Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank"), which requires companies to disclose their use of conflict minerals emanating from the Conflict Region beginning on May 31, 2014.

Conflict minerals include tantalum, tin, tungsten and gold. The mining of conflict minerals has resulted in human rights abuses and the proceeds from such mining operations are being used to finance regional conflicts. The disclosure requirement found in Section 1502 of Dodd-Frank is intended to dissuade companies from continuing to engage in trade that supports human rights abuses and regional conflicts by requiring companies to identify the source of such minerals.

Our Commitment to Responsible Sourcing

Escalade, Incorporated and all of its subsidiaries support Congress's initiative to end trade that supports human rights abuses and regional conflicts. To comply with Dodd-Frank Section 1502, we obtain information from each of our suppliers who manufacture products that contain metals to determine the origin of the metals in such products. Based upon information provided by our suppliers, now and in the future, Escalade does not and will not knowingly use conflict minerals derived from the Conflict Region in our products.

Our Expectations of Suppliers

Suppliers of metals (including specifically gold, tin, tantalum, and tungsten) used in the manufacture of Escalade products must demonstrate to us that they understand the conflict minerals laws and will not knowingly procure specified metals that originate from the Conflict Region.

We require all of our suppliers of products containing metal to review and agree to our Vendor Agreement Letter, in which the supplier, among other things, represents and warrants to us that the supplier is in full compliance with Section 1502 of Dodd-Frank and has implemented a conflict minerals policy, due diligence frameworks and management systems to ensure continuing compliance with Section 1502 of Dodd-Frank.

Pursuant to the Vendor Agreement Letter, each supplier also must provide to us written evidence of due diligence documentation relating to the source of metals contained in any product supplied to us. If a product contains conflict minerals, the supplier must complete the Electronic Industry Citizenship Coalition Conflict Minerals Reporting Template and return it to us in a timely manner. These measures allow us to effectively identify and assess risk in the supply chain and proactively respond to any identified risk.

Our Conflict Minerals Compliance Program

Additionally, Escalade has implemented a Conflict Minerals Compliance Program that incorporates the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. Such Guidance includes a five-step framework that we have adopted, which includes: (1) establishing strong management systems, (2) identifying and assessing risk in the supply chain, (3) designing and implementing a strategy to respond to identified risk, (4) carrying out independent third-party audit of smelters/refiners' due diligence practices, and (5) reporting annually on supply chain due diligence.

Additional Information

Escalade is committed to ensuring the safety, health and protection of people and the environment worldwide. We promote these principles in our global business practices and our code of conduct.

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