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Corporate

Corporate Responsibility

Social Responsibility

Just as we continually strive to create high-performing and innovative products, we also seek to follow the law on social issues important to our employees, shareholders and customers. This includes raising awareness with our employees and within our supply chain about how we can make the right decisions on issues like product safety and work environments affecting those who help us make our products.

Supplier Responsibility

Callaway Golf strives to follow the applicable law on socially responsible business practices among our employees and throughout our supply chain. Our Supplier Code of Conduct is designed to educate our suppliers about the importance of providing safe working conditions, treating workers with respect and using responsible manufacturing processes.

If you have any questions about our supplier responsibility efforts, please send inquiries to corporatecompliance@callawaygolf.com.

Children's Products

We test and certify compliance of children’s products according to the Consumer Product Safety Improvement Act of 2008 (CPSIA) and use guidance provided by the Consumer Product Safety Commission (CPSC).

CPSIA Certificate Lookup

We work closely with certified laboratories to test the materials in our products against current regulatory requirements. We also require our suppliers to follow these requirements. If you have any questions about compliance for Callaway Golf children’s products, please send inquiries to corporatecompliance@callawaygolf.com.

Transparency in Supply Chains Act

Effective January 1, 2012

ABOUT THIS POLICY

This policy describes Callaway Golf's response to California's Transparency in Supply Chains Act of 2010. On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) went into effect in the State of California. This law describes the information to be made available by manufacturers and retailers regarding their efforts (if any) to address the issue of slavery and human trafficking. Click to view California's Transparency in Supply Chains Act of 2010.

CORPORATE AND SUPPLIER CODES OF CONDUCT

Company Code of Conduct
The Company's Code of Conduct is part of Callaway Golf Company's effort to conduct its global business legally. The Code applies to all board members, officers and employees of Callaway Golf Company and its subsidiaries. All Callaway Golf Company employees are required to comply with the Company's Code of Conduct, which includes provisions designed to address the principle that child, prison, or forced labor are not permitted at any Callaway Golf Company supplier operation. Callaway Golf Company's Code of Conduct is applicable throughout the world, and the Company trains employees on these standards from time to time, including new hire training for all incoming employees and ongoing training of all company employees and management who have direct responsibility for supply chain management. This ongoing training specifically addresses education on human trafficking and slavery prohibitions within the product supply chain.

Click to view the Company's Code of Conduct.

Supplier Code of Conduct
The Company has also adopted and implemented a "Supplier Code of Conduct." The Supplier Code of Conduct describes the business practices and employment standards applicable to Callaway Golf's direct suppliers on a global basis. Click to view the Supplier Code of Conduct.

Direct suppliers receive copies of or have access to the Supplier Code of Conduct and many suppliers post the Code on site at their various locations.

HOW WE VERIFY COMPLIANCE

The Company uses various approaches to verify the absence of forced labor and child labor in our supply chain, including the following:

Supply Chain Qualification and Supplier Assessments 
Callaway Golf Company performs assessments of potential suppliers according to a risk-based approach. This approach includes preliminary risk assessments and supplier assessment questionnaires. New supplier screenings are generally conducted internally by Callaway Golf Company personnel. Ongoing supplier compliance is typically monitored by a combination of measures (as discussed below), including supplier self-assessments, Callaway Golf Company-conducted audits and third party audits. Callaway Golf Company uses tools such as regular questionnaires (which are administered by Callaway through a web-based service), that are completed by direct tier one suppliers and selected tier two suppliers.

Supplier Audits 
Callaway Golf Company's audit program evaluates suppliers' compliance with the Company's Supplier Code of Conduct. Various types of announced audits are conducted under this program, including onsite audits conducted or attended by Callaway Golf Company personnel, collaborative or self-audits, and periodic third-party on-site audits of practices and underlying management systems. If deficiencies are identified, suppliers are directed to produce corrective action plans. The corrective action plans typically outline how a supplier will resolve issues uncovered in audits. If any compliance issues are identified, the Company may terminate the supplier relationship or will require action by the supplier to rectify the problem within a designated timeframe.

Currently, site audits are scheduled at most direct supplier sites every two years. These audits are conducted by Callaway Golf Company or by a third party auditing company. The audits are semi-announced audits. This means that the suppliers are given a window of time when the audit will take place, but the exact date of the audit within the timeframe is unannounced.

Terms and Conditions in Purchase Orders and Agreements 
Callaway Golf Company has various agreements or purchasing terms and conditions in place with most direct suppliers, requiring them to comply with applicable laws and regulations, including laws regarding forced labor and child labor.

Corporate Purchasing Policy
Callaway Golf Company has a Corporate Purchasing Policy in place that applies to all US employees responsible for commitment of funds to external suppliers. The Policy also serves as a guide for all non-US employees. Applicable employees are responsible for understanding and complying with this Policy. Among other things, the Policy is designed to promote compliance with all applicable federal, state and local laws and regulations.

Supplier Certifications 
Over the course of the next 12 to 18 months (through 2013), Callaway Golf Company is introducing a program to require 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.

Product Compliance
Callaway Golf Company strives to ensure products comply with applicable laws and regulations through education, testing, certifications and audits.

Conflict Free Sourcing
Callaway Golf Company has policies and procedures to reasonably assure that the use of the tantalum, tin, tungsten and gold in the products manufactured do not directly or indirectly finance armed groups in Covered Countries as defined by the Conflict Minerals Rule issued by the U.S. Securities and Exchange Commission (SEC) under the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Click to view Callaway’s Conflict Mineral Policy.

Employee and Supplier Training
Callaway Golf Company educates employees responsible for supplier programs on how to identify and report compliance issues. Callaway Golf Company also strives to educate suppliers on relevant regulatory requirements, programs and Company policies.

Company Legal Compliance Committee and Internal Audit Department
Callaway Golf Company has formed a Legal Compliance Committee to address compliance issues on a global basis and to develop systems and procedures to address any ongoing compliance issues in the locations where we conduct operations. The Legal Compliance Committee meets on a regular basis and the Chief Ethics Officer provides updates of key findings to the Callaway Golf Company Board of Directors.

The Company also has an Internal Audit Department that periodically tests supplier compliance with contract terms through a variety of methods. The Company also seeks to promptly address internal accountability standards and procedures for employees or contractors failing to meet Callaway Golf Company standards.

POLICY UPDATES

From time to time we may change our practices under this policy. We will try to post the latest version of this policy here.

HOW TO CONTACT US

If you have any questions about this policy, you can email us at corporatecompliance@callawaygolf.com. If you would like to write to us, our U.S. address is:

Compliance Question
Callaway Golf Company
2180 Rutherford Road, 
Carlsbad, California 92008