Corporate Policy of Engagement

A. Objectives

1. ASICS expects all of its business partners, which include but are not limited to ASICS' suppliers and subcontractors (‘ASICS Business Partners’), to operate their businesses in line with the principles set out in ‘ASICS Vision’, ‘ASICS Philosophy’ and the ‘ASICS Code of Conduct’.

2. The purpose of this policy is to establish and to ensure that ASICS Business Partners comply with ASICS' policy regarding the minimum requirements relating to human rights, labour, health, safety and environmental issues at all facilities operated by ASICS Business Partners. This policy is based on ‘ASICS Vision’, ‘ASICS Philosophy’, the ‘ASICS Code of Conduct’ and the model Code of Conduct issued by the World Federation of the Sporting Goods Industry (WFSGI).

3. ASICS will assess all ASICS Business Partners on the basis of their compliance with this policy. As such, this policy is a tool that enables ASICS to select and retain ASICS Business Partners that follow business practices which are consistent with ASICS’ policies and values.

B. Standards

1. General principle: ASICS Business Partners are to operate in full compliance with all national and local laws, rules and regulations as are applicable to their business operations.

2. Employment standards: As regards the employment of any and all employees of ASICS Business Partners (‘Employees’), ASICS Business Partners are to comply with the following standards:

a) Forced Labour: ASICS Business partners shall not make use of forced labour, either in the form of prison labour, indentured labour, bonded labour, or any other form. No Employee can be compelled to work through force, the threat of force or intimidation of any kind.

b) Child labour: ASICS Business Partners shall not employ persons under the age of 15 (or 14 where employment at the age of 14 is permitted by the relevant laws), nor shall they employ persons who have not yet reached the age at which they should complete compulsory education in the country in which they are employed where such age is higher than 15.

c) Harassment or abuse: ASICS Business Partners must acknowledge that their Employees have the right to a workplace where there is no physical, sexual, psychological or verbal harassment or abuse and are to treat Employees with respect and dignity.

d) Discrimination: when employing or hiring, the salaries, benefits, promotion, training, discipline or conditions of termination or retirement offered by ASICS Business Partners shall not show any discrimination based on gender, race, religion, age, disability, sexual orientation, nationality, political opinion, or social or ethnic origin.

e) Right of association and collective bargaining: ASICS Business Partners shall recognize and respect the rights of Employees' to organise and join associations of their own choosing, and to bargain collectively.

f) Wages: ASICS Business Partners must recognise that Employees are to be fully remunerated for all time worked and must be provided with a clear written payslip showing details of their pay for each pay period. ASICS Business Partners shall pay Employees at least a) the minimum wage required by law or b) the prevailing industry wage, whichever is the higher. In addition to remuneration for regular hours of work, for overtime hours Employees are to be paid at least the premium rate required by law or, in those countries where such laws do not exist, a rate that exceeds the regular hourly rate.

g) Hours of work: including overtime, ASICS Business Partners shall not require their Employees to work more than sixty hours a week or the maximum working week established by the relevant law, whichever is shorter, on a regular basis. ASICS Business Partners are to give Employees at least one day off in every seven-day period on a regular basis and paid annual leave as required by the relevant law.

h) Benefits: ASICS Business Partners are to see to it that their Employees receive all legally mandated benefits.

i) Health and safety: ASICS Business Partners are to provide a safe and healthy working environment, which includes but is not limited to adequate lighting, heating and ventilation systems and protection from fire, accidents, and hazardous substances. ASICS Business Partners' Employees must have access to clean and adequate sanitary facilities at all times. Where residential facilities are provided for Employees, the same standards apply.

3. The environment: ASICS Business Partners are to comply with all applicable environmental legislation and regulations and must work to further improve environmental conservation. Furthermore, ASICS Business Partners are to run their businesses with due consideration for health and safety and the environment by saving resources and energy, reducing emissions, showing due concern for the environment when purchasing and by preventing pollution.

C. Publicity

ASICS Business Partners are to make every effort to ensure that their Employees understand this policy by informing Employees of this policy orally, and by distributing written copies of this policy, or by displaying this policy, translated into the local languages spoken by Employees, in a prominent place in the workplace.

D. Documentation and inspection

ASICS Business Partners are to maintain all documents necessary to demonstrate compliance with this policy and any applicable laws, and must submit these documents to ASICS upon request. Furthermore, ASICS has the right to conduct inspections or to have a designated independent inspector conduct such inspections with or without prior notice in order to ascertain that ASICS Business Partners are complying with ASICS standards and the applicable laws. ASICS Business Partners are obliged to accept such inspections.

ASICS group companies are to operate their businesses in accordance with the principles set out in this policy.