Supplier Code of Conduct & Standards
This Code of Conduct and Standards reflects Summit Golf Brands' commitment to respect for people, protection of the environment, and responsible product development. We believe our products should be made under conditions that uphold human dignity, safeguard worker health and safety, minimize environmental impact, and ensure the long-term trust of consumers.
Compliance with this Code is a fundamental condition of partnership with Summit Golf Brands. By accepting our purchase orders, you acknowledge receipt of this Code and commit to full compliance with its requirements.
As our partner supplier, you are expected to:
- Communicate this Code to relevant management and workers in an understandable language
- Maintain accurate records and transparent practices
- Promptly address and remediate any non-compliances
- Cooperate fully with audits, assessments, and corrective action processes
This Code remains in effect unless amended or replaced by Summit Golf Brands in writing. Continued acceptance of purchase orders constitutes acceptance of any updates.
Purpose & Scope
This Code establishes minimum mandatory social, labor, environmental, chemical, product safety, and ethical requirements for all Tier 1 Suppliers that manufacture apparel or apparel components directly for Summit Golf Brands — including cut-and-sew factories, vertically integrated facilities, and finishing facilities.
Tier 1 Suppliers are responsible for ensuring compliance across all production activities, including those at subcontracted or outsourced facilities. Unauthorized subcontracting is strictly prohibited. Any subcontracting must be expressly authorized in writing by SGB.
Sustainability Commitment
SGB is committed to environmental protection, responsible resource use, ethical labor practices, and long-term supply chain resilience. SGB maintains an Environmental Management System designed to promote legal compliance, reduce environmental impact, and support continuous improvement across operations and the supply chain.
Suppliers must support SGB's sustainability goals by complying with all applicable environmental, labor, and chemical laws, and by operating their facilities in an environmentally and socially responsible manner.
Vendor Code of Conduct Requirements
All vendors and suppliers involved in the manufacture of SGB products must carry out activities in an ethical, lawful, and responsible manner. At a minimum, vendors are required to:
- Provide safe and healthy working conditions
- Treat all workers with dignity and respect, free from abuse, harassment, or unlawful discrimination
- Comply with all applicable federal, state, local, and international laws relating to labor, health and safety, environment, chemical management, and business ethics
- Maintain effective systems and controls to ensure ongoing compliance with this Code
Failure to meet these requirements may result in corrective action, suspension, or termination of the business relationship.
Labor & Human Rights
SGB requires all suppliers to respect internationally recognized human rights and to operate in compliance with all applicable labor and employment laws and the Fundamental Conventions of the International Labour Organization (ILO).
Freely Chosen Employment
All work must be voluntary. Workers must be free to enter into and terminate employment with reasonable notice and without penalty, coercion, or restriction.
- Forced, bonded, indentured, trafficked, or prison labor
- Retention or confiscation of worker passports, identity documents, or personal property
- Charging workers any recruitment fees or related costs at any stage of employment
Child Labor & Young Worker Protections
Suppliers must not employ any individual below the legal minimum working age. Robust age-verification procedures must be implemented and maintained. Workers under 18 must not be employed in:
- Hazardous work or conditions, including exposure to hazardous chemicals
- Night work or excessive overtime
- Work that may interfere with their education, health, safety, or development
Working Hours
Suppliers must comply with all applicable laws governing working hours, rest periods, and overtime. At a minimum:
- Workers must receive at least one day off in every seven-day period
- Overtime must be voluntary, limited, and compensated at legally required rates
- Workers must not be required to work excessive hours on a regular basis
Wages & Benefits
Suppliers must pay all workers accurately, in full, and on time, with clear wage statements detailing hours worked, rates, overtime, deductions, and net pay.
- Wages that meet or exceed applicable legal minimums or collective bargaining rates
- All legally mandated benefits
- Wage deductions as a disciplinary measure
- Withholding or delaying earned wages or benefits, or making unlawful deductions
Harassment, Abuse & Disciplinary Practices
Suppliers must maintain a workplace free from harassment, abuse, and intimidation. All disciplinary practices must be fair, documented, proportionate, and lawful.
- Physical, verbal, sexual, or psychological abuse
- Threats, intimidation, or coercion
- Gender-based violence, sexual harassment, or degrading treatment
- Corporal punishment
Freedom of Association & Collective Bargaining
Suppliers must respect workers' rights to freedom of association and collective bargaining. Where legal restrictions limit these rights, suppliers must enable lawful alternative means for worker representation and engagement. Suppliers must not interfere with, discriminate against, or retaliate against workers for exercising these rights.
Grievance Mechanisms & Non-Retaliation
Suppliers must provide workers with accessible and effective mechanisms to raise concerns without fear of retaliation. Grievance mechanisms must be:
- Accessible to all workers
- Confidential and impartial
- Clearly communicated to the workforce
- Capable of addressing concerns in a timely and appropriate manner
Legal & Regulatory Compliance
Legal and regulatory compliance is a non-negotiable condition of doing business with SGB. Where legal requirements differ across jurisdictions, suppliers must apply the standard that provides the highest level of protection to workers, consumers, and the environment.
Applicable Laws & Regulations
Without limitation, suppliers must comply with applicable apparel-related laws including:
- CPSIA – Consumer Product Safety Improvement Act: product safety and third-party testing for children's products
- FFA – Flammable Fabrics Act: flammability standards for textiles and apparel
- Textile & Labeling Acts – Fiber content, country of origin, and manufacturer identification requirements
- FHSA – Federal Hazardous Substances Act: regulation of hazardous substances in consumer products
- TSCA – Toxic Substances Control Act: chemical reporting and PFAS compliance obligations
- California Proposition 65 and comparable state chemical disclosure laws
- UFLPA – Uyghur Forced Labor Prevention Act: prohibitions on goods made with forced labor
- State EPR Laws – Extended Producer Responsibility laws, where applicable
Anti-Bribery & Anti-Corruption
Suppliers must conduct all business activities with integrity. The offering, giving, requesting, or receiving of any bribe, kickback, or improper payment — in cash or in kind — is strictly prohibited. Suppliers must comply with the U.S. Foreign Corrupt Practices Act (FCPA) and all applicable local anti-corruption laws.
Trade Compliance & Export Controls
Suppliers must comply with all applicable trade, customs, and export control laws, including where applicable:
- EAR – U.S. Export Administration Regulations
- OFAC – Office of Foreign Assets Control sanctions programs
- CSL – Consolidated Screening List screening requirements
- FTA – Free Trade Agreement rules of origin and documentation requirements
Environmental, Social & Governance (ESG) Compliance
Environmental Compliance
- Comply with all applicable environmental laws and permit requirements
- Adhere to chemical and hazardous substance restrictions, including PFAS requirements
- Implement controls to manage waste, emissions, wastewater, and hazardous materials
- Maintain documentation demonstrating environmental compliance
Social Compliance
Suppliers must comply with the labor and human rights requirements set forth in this Code and with all applicable labor and employment laws. Social compliance obligations are enforceable and subject to audit and verification.
Governance, Transparency & Cooperation
- Conduct business transparently and maintain accurate, complete records
- Cooperate fully with SGB audits, assessments, and verification activities
- Maintain internal policies, controls, and training programs for ongoing compliance
- Promptly disclose any actual or suspected violations of law or this Code related to SGB products
Audit, Monitoring & Right of Access
Suppliers must permit SGB or designated third parties to conduct announced or unannounced audits to verify compliance with this Code, applicable laws, and contractual requirements. Suppliers must:
- Grant access to relevant facilities, processes, and records
- Allow private interviews with workers, with or without management present
- Provide accurate, complete, and unaltered documentation upon request
- Cooperate fully with audit activities, corrective actions, and verification processes
Any falsification of records, coaching of workers, or obstruction of audits may result in immediate suspension or termination of the business relationship.
Environmental & Chemical Compliance
PFAS & Hazardous Substance Restrictions
Suppliers must comply with all applicable laws governing the use, disclosure, and restriction of hazardous substances, including per- and polyfluoroalkyl substances (PFAS).
Authorized PFAS Use: PFAS is permitted only in products expressly designated and approved in writing by SGB for performance in extreme wet conditions, and only where legally permitted.
PFAS-Free Statement Requirement: For all products not designated for authorized PFAS use, suppliers must:
- Submit a signed PFAS-Free Statement confirming no intentionally added PFAS are present
- Ensure all materials, trims, coatings, finishes, and treatments are free from intentionally added PFAS
- Update the PFAS-Free Statement if any changes occur to materials, components, or sourcing
Product Safety, Chemical Compliance & Documentation
Product Safety & Regulatory Compliance
All products manufactured for SGB must:
- Comply with applicable product safety laws, including flammability, chemical safety, and consumer protection requirements
- Be accurately and legally labeled with fiber content, country of origin, and care instructions
- Meet applicable legal requirements related to hazardous substances and consumer disclosure
Testing, Certification & Recordkeeping
Where required by law, regulation, or SGB request, suppliers must:
- Conduct product testing using qualified or accredited laboratories
- Provide valid test reports, Certificates of Compliance (COCs), Certificates of Analysis (COAs), and Safety Data Sheets (SDS)
- Maintain records demonstrating compliance, traceability, and accuracy of certifications for the duration required by applicable law
Enforcement, Corrective Action & Remedies
Failure to comply with this Code may result in corrective action, including:
Suppliers are responsible for promptly addressing non-compliances and implementing corrective actions as directed by SGB.
Relationship to Other SGB Compliance Requirements
This Code establishes Summit Golf Brands' minimum mandatory standards. Additional requirements may be set forth in SGB policies, manuals, testing protocols, purchase order terms, and other compliance documents. In the event of a conflict, the stricter or more protective requirement shall apply unless otherwise expressly stated in writing by SGB.
This Code does not limit SGB's right to impose additional requirements or take corrective action where necessary.