pg. 2-3

"Governance and Policies

Our system of governance ensures that our human rights principles and objectives are embedded throughout our business. This is a shared responsibility involving all company divisions and colleagues at every level. We conduct our corporate activities on the basis of clear codes of conduct that are based on internationally recognized standards and conventions. Suppliers have to understand and acknowledge these standards and are formally obliged to meet them. We seek to work only with business partners who share our commitment to sustainability and fair labor practices.

Our Policy of Engagement (PoE), which at ASICS is our supplier Code of Conduct, sets out the minimum requirements regarding human rights, labor standards, occupational health and safety and environmental practices for any ASICS business partner. The requirements include specific expectations that address forced labor and child labor and human trafficking. Our PoE requires any partner involved in the manufacturing of ASICS Group branded products to:

• Respect worker rights and be in full compliance with all laws, regulations and administrative instructions applicable to their business operations.

• Maintain all relevant documents necessary to demonstrate compliance with our policies. When deemed necessary ASICS or its contracted independent monitors shall be allowed, regardless of prior notice, to conduct compliance assessment audits.

• Employees shall be provided with safe and decent working conditions, fair wages and secondary benefits and be treated with respect.

This also means that our partners:

• Shall not use forced labor, whether in the form of prison labor, indentured labor, bonded labor, or otherwise. No Employee can be compelled to work through force, the threat of force or intimidation of any form.

• Employees should not bear the cost for their employment whether in the form of recruitment fees or other; should retain control of their travel documents and have full freedom of movement.

Over and above ASICS’ Policy of Engagement and other supplier requirements and expectations, our ASICS Code of Conduct sets out the basic standards by which all members of ASICS Group must comply during their daily activities and with each business decision. All directors, officers and employees in the ASICS Group are required to review, understand and comply with this Code.

We continuously improve audit functions and internal controls of our corporate management. Our aim is to create a management approach that goes beyond compliance and reflects the perspectives of our stakeholders.

We encourage employees and business partners to report code or policy violations using our confidential, anonymous whistleblowing services. This allows us to detect the first signs of wrongdoing quickly and carry out corrective measures without delay."

pg. 4

"ASICS continuously monitors Tier 1 and major Tier 2 suppliers to evaluate compliance with its company standards including standards to prevent the incidence of modern slavery, human trafficking and child labor in our supply chains."

I added prohibition of child labour in direct suppliers because the company states that the supplier code of conduct include specific expectations that address child labour even if not described in detail. (see p. 3)

The original comments stated that beyond tier 1 was checked in the answers to this metric because the company monitored some Tier 2 companies' compliance with the company's standards. However, such standards only refer to incidence of modern slavery, human traffiking and child labour and do not make reference to the PoE, that is the supplier code of conduct (see p. 4). Therefore, I have unticked the beyond tier 1 for those options that are not mentioned there and left them as direct tier 1.

I also unticked contracts include clauses and protection of migrant workers as I found no evidence of it.

Sofia Gonzalez De Aguinaga.....2021-12-07 22:52:17 UTC