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COBRA PUMA Golf’s Practices Consistent with California Anti-Slavery Law

December, 2011

In September 2010, the State of California approved a new law, which will require retailers and manufacturers operating in the state to make public the steps they have undertaken to eradicate slavery and human trafficking from their supply and distribution chain. In line with the California Transparency in Supply Chains Act (SB 657), Cobra PUMA Golf recognizes the pervasiveness of practices that could be construed as slavery and human trafficking and is committed to addressing the issues within its supply chain.
Cobra PUMA Golf acknowledges the levels and types of risks related to each country where its materials and goods are sourced and produced. Cobra PUMA Golf has in place a factory monitoring system to ensure compliance to Cobra PUMA Golf’s Code of Conduct. Our Code of Conduct covers issues such as maximum working hours, basic wage, respect, equality and restriction of forced labor amongst others.

Furthermore, within our agreements, every factory which manufactures Cobra PUMA Golf products is audited for compliance with all Cobra PUMA Golf standards and the relevant national and local laws – including those related to anti-slavery and human trafficking. Where such laws do not yet exist, Cobra PUMA Golf strives to engage with all relevant stakeholders to come up with policies and actions to address the issue.

At present, our Safe audit process is the primary tool to ensure that Cobra PUMA Golf’s social, health, safety and environmental standards are observed at our contract factories as well as its subsidiaries, licensees or subcontractors. During the audit, workers are interviewed and amongst other topics they are asked how they obtained their job, if they had to pay any fees and if they were given back their identification documents. Foreign workers’ working permits are also reviewed. If there are dormitories in the factory these are also checked and the working hours records are thoroughly reviewed. All of these actions help to verify that there is no human trafficking and slave labor.

Our factories are also subjected to compliance audits by the Fair Labor Association (FLA), which at present are all unannounced visits. The main component of both the Safe and FLA audits is the remediation of the areas of failure. To achieve sustainable compliance, our factories are obliged to address not only the areas of failure but the root causes of the failures. Where such root causes go beyond the factory walls Cobra PUMA Golf encourages our suppliers to engage with stakeholders that can help address these root causes on their own or in partnership with us. Cobra PUMA Golf also supports capacity building projects and conducts regular consultation with factories to improve the level of compliance.

The PUMA.Safe program was established over 10 years ago. Cobra Golf Incorporated became part of the PUMA. Safe program when it was acquired by PUMA. In the event that a case of human trafficking or slavery would be detected in Cobra PUMA Golf’s supply chain, the Safe team together with the factory management would seek to eradicate the practice and launch a fair remediation for the affected parties.

In accordance to the new law SB 657, Cobra PUMA Golf is dedicated to expand its standards and take measures to cover the necessary scope and beyond in efforts to eradicate slavery and human trafficking in our immediate supply chain and eventually beyond. This will include strengthening and making more explicit Cobra PUMA Golf’s workplace standards and policies for the manufacturers.

The new law, SB 657, will go into effect on January 1st, 2012.