4. Due diligence processes in relation to slavery and human trafficking in its business and supply chains

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.

5. The parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage that risk

Our suppliers are risk evaluated based upon the following criteria:

Location of factory (less developed countries receiving higher scrutiny)

Type of product being supplied to Acushnet

Size of purchasing program with supplier

Size of Acushnet Company volumes at the factory – negligible volumes or significant

Type of factory structure (ie. Single floor versus multiple floor)

Past audit results