UK MODERN SLAVERY ACT

UK Modern Slavery Act

Effective: March 2019

PING is committed to being the unquestioned leader in innovation, design, service and quality while providing an enjoyable environment for employees that allows them to fulfill their potential. PING expects its Contractors, Suppliers and Licensees, and each of their subcontractors and suppliers (collectively “CSL”), to share PING’s commitment to strive for the highest levels of product excellence and social responsibility.

PING distributes golf products, accessories, and apparel throughout the world. Components and products are sourced, manufactured, and assembled from contract suppliers as well as at company owned and operated facilities.
 

Responsible Sourcing Program

The PING Code of Conduct (“Code”) establishes that PING has a desire to only do business with CSLs that comply with the legal requirements applicable to the conduct of their business and who respect accepted international labour standards. Any CSL that wishes to establish and/or maintain a business relationship with PING shall agree to be bound by PING’s Code. The Code includes, among other elements, direct language forbidding potential forms of modern slavery and human trafficking, forced labour, child labour, harassment, and coercion and it is translated into the native languages of our key suppliers.

The PING Responsible Sourcing Program, PING Restricted Substance Program and CSL Relations Group were developed to facilitate CSL commitment to the Code and provide management and oversight responsibility for CSL accountability. PING has dedicated staff and resources to develop processes and procedures aimed at assuring CSL compliance with the Code and the PING Restricted Substance Program.
 

Supplier Qualification

PING implements a risk-based approach to evaluate and qualify potential suppliers. Tools used in this process generally include self-evaluations, on-site risk assessments, and supplier visits to verify and validate actual practices. Potential direct supplier qualification activities are managed by PING personnel.
 

Supplier Monitoring

Evaluation of supplier compliance with the Code is monitored through the use of self-assessment questionnaires and PING conducted supplier audits. While PING reserves the right to conduct unannounced audits, in general, typical audits of direct tier one suppliers and nominated tier two suppliers are announced. In addition, PING is a Fair Labor Association (FLA) affiliate and audits may also be conducted of PING’s collegiate suppliers by the FLA. Visit www.fairlabor.org more information.

The decision to conduct audits and the frequency of audits is based on risk factors such as the nature of the supplier relationship, factory locations, awarded business, the results of previous audits, and the history of compliance and improvements. Industry standard audit tools are used and include audit guidelines and checklists, site walkthroughs, and interviews with management and other employees. Audit reports are generated, corrective action plans are agreed to for applicable findings, and improvements are tracked.

PING strives to support our supplier's efforts to develop lasting and sustainable solutions. As a routine component of the audit process, the PING audit team assesses and evaluates the knowledge, skills, tools, and resources available at the supplier to improve processes. Where applicable, PING can assist through training and knowledge transfer.
 

Supplier Certification

Purchase Order Terms and Conditions require direct supplier compliance with PING's Restricted Substance Program, Code of Conduct, Foreign Corrupt Practices Act, as well as other applicable laws and regulations.
 

Training

PING compliance staff attend training sessions provided by the FLA and are involved with industry and trade groups focusing on social compliance issues.

PING periodically educates and trains employees on the Code of Conduct, compliance issues, and social responsibility programs.

John-Clark-Signature.jpg
John Clark
Managing Director

27 March 2019

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