Acushnet Company and its subsidiaries (collectively, “Acushnet”) are committed to operating our business responsibly and ethically, with due consideration for our associates, stockholders, customers, suppliers, and the communities in which we operate. We strive to integrate this commitment into all aspects of our business, including the design, quality, safety, and sourcing of our products; the health, safety, development, and fair treatment of our associates; our pursuit of environmentally responsible practices; volunteerism and philanthropic engagement in our communities; and our strict adherence to applicable laws, regulations, and recognized best practices.

This commitment includes, but is not limited to:

• Compliance with applicable laws and regulations, including required environmental permits and product safety requirements; and
• Promotion of, and adherence to, Acushnet’s Code of Conduct and Supplier Code of Conduct throughout our supply chain.

Our Global Human Rights Policy and our long-standing Supplier Citizenship Policy (available on our website at www.titleist.com/corporate-responsibility under “Supplier Review Program”) establish expectations for both our associates and suppliers with respect to human rights, labor standards, workplace health and safety, and environmental protection. We expect all associates and suppliers worldwide to conduct business in accordance with these policies and in compliance with applicable national, international, and local laws and regulations.

Suppliers are selected and monitored, in part, based on their adherence to these policies. Acushnet communicates its global citizenship and supplier expectations to all suppliers and conducts appropriate levels of compliance review based on supplier risk profiles. To verify compliance, or progress toward compliance, we conduct supplier audits in accordance with our Supplier Review Program.

To ensure that our products remain compliant with regulations within a rapidly evolving global regulatory landscape, Acushnet continuously and proactively monitors regulatory lists of toxic and hazardous substances through regulatory tracking databases and alert services to identify substances that may pose potential risks to our products. Ingredients are reviewed on an ongoing basis to confirm that such substances are either not present or are included only at levels below applicable regulatory thresholds. This monitoring is supplemented by product testing when necessary and written supplier certifications attesting to the absence of regulated or harmful substances above threshold levels, including, where applicable, TCLP constituents, REACH Restricted Substances or Substances of Very High Concern (SVHCs), and substances regulated under the Toxic Substances Control Act, among others.

Acushnet maintains a rigorous product safety testing program designed to verify compliance with applicable chemical, material, and performance standards. Testing is conducted through a combination of internal quality assurance reviews and independent, accredited third-party laboratories. Products and components are tested at regular intervals throughout the product lifecycle, including at the design and development stage, upon introduction of new materials or suppliers, and in response to changes in applicable regulatory requirements.

When a potential product compliance concern is identified — whether through regulatory monitoring, supplier audits, internal testing, or customer feedback — Acushnet acts promptly to assess and address the issue. Depending on the nature and severity of the concern, our response may include supplier remediation requirements, suspension or termination of supplier relationships, reformulation or redesign of affected products, and, where warranted, withdrawal of products from the market.

Acushnet is committed to the continuous improvement of our product compliance program. We provide regular training to associates involved in product development, sourcing, and supply chain management to ensure awareness of applicable regulatory requirements and internal compliance standards. Our product compliance team monitors developments in global regulations and industry best practices, and updates our policies, procedures, and testing protocols accordingly. We believe that a well-informed workforce and a culture of accountability are essential to delivering safe, compliant products to our customers and communities around the world.