Room 1.01

Leggett & Platt, Incorporated

Conflict Minerals Report

For the reporting period from January 1, 2021 to December 31, 2021

This Conflict Minerals Report (the “Report”) of Leggett & Platt, Incorporated (the “Company”, “we”, “us” or “our”) has been prepared pursuant to 13p-1 and Form SD (collectively the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period of January 1, 2021 through December 31, 2021.

The rule requires disclosure of certain information when a company manufactures, or agrees to manufacture, products containing certain minerals specified in the rule that are necessary for the functionality or production of those products. These minerals, which we refer to collectively in this report as “conflict minerals”, are columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, which are limited to tantalum, tin and tungsten. The “countries covered” for the purposes of the rule and this report are the Democratic Republic of the Congo, Angola, Burundi, the Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia.

The information contained in this report includes the activities of the Company and its subsidiaries during the reporting period, excluding Kayfoam Woolfson Unlimited Company (“Kayfoam”) and Avica Aerospace Ducting Limited (“Avica”). Kayfoam and Avica were acquired on or after May 1, 2020 and were not required to provide a specialist conflict minerals disclosure report. In accordance with Instruction 3 of Item 1.01 of Form SD, these entities have not been included in this filing because they were acquired less than eight months after the start of the reporting period.

The company

We are a global manufacturer with facilities located around the world. Our manufacturing plants are located in Austria, Belgium, Brazil, Canada, China, Croatia, Denmark, France, Hungary, India, Ireland, Mexico, Poland, South Korea, in Switzerland, the United Kingdom and the United States. Our operations are organized into 15 business units, which are divided into seven groups under three segments: Bedding Products; Specialized products; and furniture, flooring and textile products.

The reasonable investigation of the country of origin of the company

Internal investigation and reasonable country of origin investigation. We conducted an internal investigation of the parts and materials we purchased from suppliers. We have assigned authority and responsibility to one or more individuals for each business unit to (a) compile an internal inventory of parts and materials that we (i) know or reasonably suspect contain necessary conflict minerals and (ii) knew that they were included in a product whose manufacture was completed during the reporting period, and (b) identify the associated suppliers. Based on our identified
“scope” suppliers, we have conducted a reasonable and good faith Country of Origin (“RCOI”) investigation of such required Conflict Minerals. This RCOI was reasonably designed to determine whether the Conflict Minerals originated from Covered Countries and whether the Conflict Minerals originated from recycled or scrap sources. We have implemented a supplier engagement approach. We have sent requests to those identified
scope suppliers for needed conflict minerals and sourcing information; smelter or refiner identification (the “SOR”); and identification of the origin of the required conflict minerals used by these SORs (i.e. country of origin, recycled or scrap, etc.). Requests were submitted through the SupplierSoft Conflict Minerals application, a web-based tool designed to report and track conflict minerals sourcing information along the conflict minerals supply chain, using the Minerals Initiative’s Conflict Minerals Reporting Template (the “RMI”) (the “CMRT”). In addition to the CMRT’s request, we distributed correspondence to each scope which briefly described the requirements of the Rule and contained an electronic link to our Conflict Minerals Policy (the “Policy”) and our Purchase Order Terms and Conditions (the “Purchase Order Terms”) (each discussed below below).


Comments are closed.