Supplier Citizenship Policy

CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT OF 2010 DISCLOSURE

This Disclosure describes Acushnet Company’s (the “Company”) efforts to ensure that slavery and human trafficking do not occur in our Company’s direct supply chain for tangible goods offered for sale.

The Company has adopted and implemented a "Supplier Citizenship Policy" which describes the business practices and employment standards applicable to the Company’s worldwide direct suppliers. Click to view the Supplier Citizenship Policy . Direct suppliers annually receive copies of the Supplier Citizenship Policy and many suppliers post the Policy on site at their various locations.

The Company uses significant efforts to verify the absence of forced labor and child labor in its supply chain, including the following:

Direct Supply Chain Verifications

The Company evaluates actual and potential suppliers according to a risk-based strategy. New supplier screenings are conducted by Company personnel.

Direct Supply Chain Audits

The Company has a multi-faceted program to audit suppliers’ compliance with the Company’s Supplier Citizenship Policy. Supplier compliance is monitored by supplier self-assessments, Company questionnaire requirements, Company personnel visits and third party audits. Many suppliers are required to report their compliance (via detailed questionnaire based reports) with the Policy either annually or bi-annually, depending on their risk profile. Various types of audits are conducted, including onsite visits by Company personnel. Periodic unannounced third-party on-site audits for many suppliers are conducted on each of the eleven categories listed in the Supplier Citizenship Policy. If concerns are identified, suppliers must produce corrective action plans describing how they will resolve issues uncovered in audits. The Company may terminate a supplier relationship if serious non-compliance is discovered (such as child or forced labor) if it is not immediately addressed or if other non-compliance continues.

Direct Supply Chain Certifications

The Company’s purchasing agreements require suppliers to comply with all applicable laws and regulations, including local laws regarding forced and child labor. In addition to the requirements of the Company’s Agreements regarding compliance issues, the Company requires direct suppliers to certify that materials incorporated into the Company's products comply with the laws of the countries where the suppliers are doing business via its questionnaires and audit/corrective action programs.

Company Internal Accountability Standards and Compliance Committee

The Acushnet Company Compliance Committee has worldwide responsibility to address compliance issues related to the Company’s business. The Compliance Committee meets regularly and develops policies and procedures for many issues, including provisions in multiple documents prohibiting child or forced labor (e.g., the Company’s Supplier Citizenship Policy and Code of Business Conduct and Ethics) and requiring immediate response, should any such circumstances be discovered in its supply chain. Failures to meet any of these standards by employees, contractors or suppliers are addressed by the Committee and by senior management of the Company. The Company will terminate employees and contractors, and it may terminate a supplier relationship if serious non-compliance is discovered (such as child or forced labor) if it is not immediately addressed or if other non-compliance continues.

Employee and Management Training

The Company has an extensive employee compliance training program and trains employees responsible for supply chain management regarding supply chain issues. All worldwide Company employees must comply with the Company's Code of Business Conduct and Ethics, which addresses the principle that child, prison, or forced labor are not permitted at any Company or Company supplier operation. The Company periodically trains employees on these standards, including training for all new employees and refresher training of all Company employees and management, including those who have direct responsibility for supply chain management.

Acushnet Company takes great pride in the integrity of its operations, including those in its direct supply chain. We strive to achieve best practices in everything that we do. Accordingly, we may periodically update this Disclosure to reflect current practices.

Acushnet Company Supplier Citizenship Policy

Introduction

At the Acushnet Company, we are dedicated to operating ethically, protecting the environment, and supporting the communities in which we do business. Our associates are guided by our Code of Conduct, which is based on our key beliefs of uncompromising integrity, values and our constant respect for people. These key beliefs are vital to the success of the Acushnet Company. To support this success, the Acushnet Company Supplier Citizenship Policy establishes guidelines that respect human rights, workplace safety and protection of the environment.

The Acushnet Company expects each of its suppliers worldwide to conduct their business activities in accordance with the elements contained in this policy. These elements are the Acushnet Company’s minimum standards and are not intended to supersede any applicable governmental regulations or requirements. Each supplier and their individual operations are expected to comply with this policy and upon request, provide evidence of compliance.

Acushnet Company Supplier Citizenship Policy Elements

  1. Working Conditions/Health and Safety
  2. Child Labor
  3. Forced Labor
  4. Discrimination
  5. Harassment and Abuse
  6. Freedom of Association and Collective Bargaining
  7. Working Hours
  8. Wages and Benefits
  9. Environmental
  10. Management Systems
  11. Suppliers/Contractors

Working Conditions/Health and Safety

  • Employees must be provided with a safe and healthy working environment. The supplier will take adequate steps, as appropriate, to reasonably prevent and minimize accidents and injuries to health within the workplace. The supplier will provide adequate means of evacuation and train employees in emergency preparedness.
  • Personnel should receive appropriate training on safety and health concerns in the workplace. Such training should be documented and include newly hired and reassigned employees.
  • If provided, the supplier will ensure that dormitory facilities are clean, safe and meet the basic needs of employees.

Child Labor

  • All workers must meet or exceed the local minimum age law requirements, but in no event shall workers under 15 years of age be employed. Depending on the nature of the work being performed, the supplier may seek to limit employment to workers over 18 years of age.

Forced Labor

  • The supplier will not allow the use of forced, bonded or involuntary prison labor.

Discrimination

  • The supplier shall prohibit engaging in or supporting discrimination in hiring, remuneration, access to training, promotion, termination or retirement based on race, national origin, caste, sexual orientation, religion, age, gender, disabilities, political affiliation or veteran status.
  • The supplier shall respect employees’ observance of tenets or practices relating to race, national origin, caste, sexual orientation, religion, age, gender, disabilities, political affiliation or veteran status.

5. Harassment and Abuse

  • The supplier shall prohibit behavior, including gestures, language and physical contact, that is sexually coercive, threatening, abusive or exploitative. These abuses include, but are not limited to, sexual harassment, corporal punishment, mental or physical coercion, and physical abuse.

Freedom of Association and Collective Bargaining

  • Suppliers must recognize and respect their employees’ rights to freedom of association and to enter into collective bargaining units.

7. Working Hours

  • Suppliers will comply with applicable local laws and industry standards on working hours; however, employees must not work more than 12 hours in a day and 6 days in a week for more than 3 consecutive weeks.
  • In addition to compensation for regular hours of work, employees shall be compensated for overtime hours at such premium rate as is legally required in the country of manufacture, or in those countries where such laws do not exist, at a rate at least equal to their regular hourly compensation rate.

8. Wages and Benefits

  • The wages and benefits offered to employees must meet or exceed the local legal minimum laws and standards.
  • Employees must be provided with clear information about their wages and benefits on a regular basis.

Environmental

  • Suppliers will conduct their business activities such that it is in compliance with applicable environmental laws, norms and regulations.
  • Suppliers will promote protection of the environment and the conservation of natural resources.

Management Systems

  • A supplier’s local policy shall be consistent with the requirements set forth in the Acushnet Company Supplier Citizenship Policy and communicated to its employees. If the supplier does not have a local policy, it shall communicate the contents of the Acushnet Company Supplier Citizenship Policy to its employees.
  • The supplier’s management system shall include practices to include investigating, addressing and responding to the concerns of employees with regard to compliance with this Policy. The supplier shall refrain from disciplining or otherwise discriminating against any employee for providing information concerning the supplier’s compliance with the Acushnet Company Supplier Citizenship Policy.
  • The supplier will periodically review the adequacy, suitability and continuing effectiveness of the systems implemented to meet the requirements of the Acushnet Company Supplier Citizenship Policy. The supplier will implement appropriate corrective actions to address any identified non-conformance.

Suppliers and Contractors

  • Acushnet Company’s suppliers will establish and maintain appropriate procedures to evaluate and select their suppliers and contractors, and where appropriate, their sub-suppliers and sub-contractors, on their ability to demonstrate evidence of conformance with the requirements of the Acushnet Company Supplier Citizenship Policy.
  • Acushnet Company’s suppliers will maintain reasonable evidence that the requirements of the Acushnet Company Supplier Citizenship Policy are being met by their suppliers and contractors, and, where appropriate, by their sub-suppliers and sub-contractors. This evidence may include certification forms, written questionnaires, audits, inspections or other appropriate documentation.

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