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    On January 1, 2012, the state of California enacted the California Transparency in Supply Chains Act (SB 657). This Act seeks to eradicate slavery and human trafficking from product supply chains. Ben Hogan Golf Equipment Company has a Vendor Code of Conduct that strictly prohibits the use of forced or compulsory labor of any kind, including prison labor, bonded labor, indentured labor, slavery and human trafficking. To address the regulations of the Act, we are taking the following steps:

     

    Verification: Ben Hogan Golf Equipment Company is committed to fair labor practices within our supply chain. Part of Ben Hogan Golf Equipment Company robust Social Compliance program is to assess and verify the risk of slavery and human trafficking within its supply chain. Ben Hogan Golf Equipment Company conducts its risk assessment by country by reviewing the US Department of State’s Trafficking in Persons Report located at http://www.state.gov/j/tip/rls/tiprpt/index.asp which is issued on an annual basis, wherein country-specific risk level assignments are based on a three-tier ranking of the local government's compliance with the Trafficking Victims Protection Act. Risk assessment is performed internally by Ben Hogan Golf Equipment Company. All direct suppliers are reviewed by Ben Hogan Golf Equipment Company’s Social Compliance Department prior to production placement.

    Audit: Ben Hogan Golf Equipment Company conducts regular audits of its direct suppliers. Ben Hogan Golf Equipment Company has established a Vendor Code of Conduct which is issued to its direct suppliers. Direct suppliers are evaluated on their compliance of our code through announced and unannounced audits conducted by Ben Hogan Golf Equipment Company's internal auditors and third party audit providers.

    Certification: As a condition of doing business, Ben Hogan Golf Equipment Company requires its direct suppliers to certify in writing via the Ben Hogan Golf Equipment Company Master Supply Agreement that they comply with all applicable laws within the country of business including those regarding slavery and human trafficking as well as Ben Hogan Golf Equipment Company's Vendor Code of Conduct.

    Accountability: Ben Hogan Golf Equipment Company maintains and enforces internal accountability procedures for Ben Hogan Golf Equipment Company employees and compliance by direct suppliers regarding company standards on slavery and human trafficking. In the case of non-compliance Ben Hogan Golf Equipment Company reserves the right to investigate the situation and develop a best possible strategy for resolution. If non-compliance continues unresolved within a timely manner, Ben Hogan Golf Equipment Company may terminate the business relationship.

    Training: Ben Hogan Golf Equipment Company conducts internal training on its Vendor Code of Conduct to ensure the necessary participants in the supply chain management are knowledgeable and aware of the issues and concerns surrounding the supply chain, involving human trafficking and slavery including mitigating risks within the supply chain of products sourced by Ben Hogan Golf Equipment Company. Ben Hogan Golf Equipment Company also encourages employees involved in PEI's supply chain to participate in external training programs and seminars on social compliance issues.