Acushnet : Code of Ethics

Code of Business Conduct and Ethics

November 2021

Dear Fellow Acushnet Associates,

Acushnet Company's reputation for conducting its business ethically and according to the highest standards is one of our most valued assets and is well earned. It has long been our culture to expect the best from all Acushnet associates when dealing with our stakeholders, including golfers, customers, suppliers, our associates and the communities in which we operate. Our compliance program is crucial to the achievement and maintenance of that reputation.

Each of us - in every country in which we operate - must foster and maintain a culture where compliance with both the law and our policies is integral to all of our business activities, including all interactions with fellow associates, with end user golfers, with our retail partners, our suppliers and any other stakeholder in our universe.

Our Code of Business Conduct and Ethics describes many of our legal and ethical responsibilities and is the cornerstone of our compliance program. Each Acushnet associate has a professional and personal obligation to follow the Code. Each of us is responsible for Acushnet's reputation and for the value we generate by the way we do business.

Please join me and the senior management team in giving your complete commitment and full support to our company compliance program. Please learn about our standards and what is expected. Live them each and every day and please feel free to contact the Legal Department or the Risk Management Committee if you have any questions.

Thank you for your continuing contributions to our collective success. I have great confidence that we will continue to do great things together - the right way.

David Maher

President and Chief Executive Officer

Table of Contents
	Page
Our Responsibility to the Company -- and to Each Other	1
Introduction - The Risk Management Committee and the Code	2
The Special Responsibility of Managers	2
Speaking Up and Resolving Issues	3
Where Can I Go for Help?	3
What Happens After a Report is Made? Are Reports Kept Confidential?	4
Can I Get in Trouble for Making a Report?	4
What if I Prefer to Remain Anonymous?	4
What if I Do Not Follow the Code?	5
What if I Think That the Code Conflicts with Local Law?	5
Our People	6
Respect for Others - Acushnet's Policies Against Harassment and Hostility	7
Health and Safety	8
Doing Business with Integrity	9
Conflicts of Interest	10
Can I Accept Business Courtesies?	10
Can I Provide Business Courtesies?	11
What Should I Consider in Selecting and Maintaining Relationships with
Business Providers?	11
Can I Work Outside Acushnet?	12
Other Conflicts of Interest	13
Antitrust and Competition Laws	14
Ethical Sales and Marketing Practices	14
International Business - Customs Laws and Prohibited Transactions - Are There
Limits on Where We Can Sell Our Products?	15
Prohibited Payments	16
Record Keeping, Financial Accuracy and Disclosure	17
Managing Assets and Information	18
Company Assets	19
Confidential Information	20
Other Parties' Confidential Information	21
Buying or Selling Securities	22
i

Personal Information and Privacy	23
Systems and Facilities Security	24
Intellectual Property	25
What About Other Parties' Intellectual Property?	25
Public Relations	26
What About Social Media?	27
Records Management, Investigations and Litigation	28
Do We Handle Documents Differently During an Investigation or Litigation?
What is a "Litigation Hold?" When Do I Need to "Hold" Documents?	28
Regulatory and Legal Inquiries	28
Our Corporate Citizenship Responsibilities	29
Environmental Concerns	30
Global Concerns	31
Training, Certification and Reporting	32
Risk Management Committee Members	32
Compliance Reporting	32
Contacting the Board of Directors	34
Acushnet Holdings Corp. Code of Business Conduct and Ethics	35
Associate Acknowledgement Certification	35

ii

Our Responsibility to the Company --

and to Each Other

We must know and comply with the Code and the law - and always act ethically.

It is each of our jobs and our responsibility to always do the right thing. Our hard work has earned our record and reputation for doing business with the highest standards. The daily choices we make decide whether we keep that reputation.

This Code is an introduction to our ethical and legal responsibilities. We must all know what the Code says and follow it. That means everyone - all associates, officers, directors, vendors, consultants and temporary workers of Acushnet Holdings Corp. (the "Company").

You must follow the Code, even if it contradicts what you are asked to do by management, even if it makes you unpopular with co-workers, even if it may create more work for you, and even if it means losing a customer or a supplier relationship.

However, the Code cannot address every issue and is not a substitute for good judgment. It guides us towards being honest and trustworthy and helps us find resources to assist in making good decisions. When confronted with an issue, asking yourself some basic questions will help you comply with our Code:

• Does the proposed action comply with the law, the Code and Company policy?
• Is my judgment free from conflicts of interest?
• Am I sure that I will not endanger myself or anyone else?
• Would I feel comfortable if I had to explain my decision to my supervisor, my family or the public or if this was in the newspaper or on the internet?
• Is this ethical and the right thing to do?

If you can answer "yes" to all of these questions, you are probably making a good decision. If you are not sure ... or if the answer is "NO" ... to any of these questions, there may be a real problem. Before you act, ask for help.

Our Responsibility to the Company and to Each Other

Introduction - The Risk Management Committee and the Code

The Risk Management Committee consists of the members of senior Company management listed on page 32 (which may change from time to time). It has general oversight responsibility and provides guidance to management concerning compliance matters and best practices in preventing and detecting unethical conduct. The Risk Management Committee's primary responsibility is to ensure that our commitment to being a good corporate citizen, embracing social responsibilities and compliance with the letter and spirit of all applicable laws and regulations continues and is enhanced.

This Code may only be materially amended by Acushnet Holding Corp.'s Board of Directors. If any officer, director, manager or supervisor attempts to orally modify the Code, or to direct action that appears to conflict with the Code, please immediately report it to the Chair of the Risk Management Committee. Any requests for waivers of the Code for associates who are not directors or executive officers must be directed through your supervisor to the Chair of the Risk Management Committee. Terms of the Code can only be waived for executive officers or directors by the Company's Board of Directors.

The Special Responsibility of Managers

Managers have more responsibility under the Code. They have a special position of trust and must set the Code compliance example, including creating an open and supportive environment where associates are comfortable raising questions or concerns and reporting misconduct.

If you are a manager, you must maintain your associates' trust that you will do the right thing. You should always be sure to:

• Be a positive role model.Act with integrity in your everyday decisions and actions.
• Raise awareness and understanding.Help those around you to identify and address risks that may arise.
• Set appropriate goals.Establish clear, measurable and challenging goals - that can be achieved without compromising our values and standards.
• Be responsive.Respond fairly, appropriately and without retaliation to anyone who raises a business conduct concern.

2

Our Responsibility to the Company and to Each Other

Speaking Up and Resolving Issues

One of the most important responsibilities of each Acushnet associate is our obligation to raise a concern about a possible violation of this Code or a Company policy, even if it is hard to do so. Our Company cannot live up to its commitment to act with integrity if we do not raise concerns when we should. The Company can be harmed not only by inappropriate actions, but also by silence when an issue should have been raised. If you are aware of a violation and do not report it, the silence condones the behavior. Accordingly, failing to report an issue is also a violation of the policy. Always speak up if:

• You are uncomfortable in a situation and need advice; or
• You believe that someone acting on behalf of the Company (including other associates, managers, consultants or suppliers) is doing - or may be about to do - something that violates our Company's ethical standards or the law.

Where Can I Go for Help?

You have choices when you need to raise a concern or issue. Your supervisor is usually a good place to start. In addition, you can also ask questions or report possible Code violations to:

• Another manager;
• The Human Resources Department;
• The Legal Department;
• Any member of the Risk Management Committee; or
• The Audit Committee of the Board of Directors, as described on page 34, if you have a finance or accounting concern.

If you are uncomfortable with any of these internal reporting channels, you have other options. You can report a Code violation, ask questions or express any compliance concern via:

• Telephone Ethics Hotlines at the numbers listed on page 33; or
• The internet at www.acushnetcompliance.com.

These resources are operated by NAVEX Global/EthicsPoint, an independent company that is experienced in handling compliance reporting issues. The telephone hotline service provider will explain to each caller procedures for following up on the report (including the caller's providing additional information at a later date).

The report should be factual rather than speculative or conclusory, and should contain as much specific information as possible to allow for proper assessment. In addition, all reports should contain sufficient corroborating information to support the commencement of an investigation, including, for example, the names of individuals suspected of violations, the relevant facts of the

3

Our Responsibility to the Company and to Each Other

violations, how the complainant became aware of the violations, any steps previously taken by the complainant, who may be harmed or affected by the violations, and, to the extent possible, an estimate of the misreporting or losses to the Company as a result of the violations.

What Happens After a Report is Made? Are Reports Kept Confidential?

Employees may make reports anonymously and confidentially and are not required to divulge their names. The Company promptly investigates all reports of Code, ethics or legal violations (and the Audit Committee investigates finance and accounting concerns) and takes corrective action when appropriate. However, it cannot act without information. If you are asked to provide information in these matters, you must cooperate fully and honestly. These matters are kept as confidential as possible, with information shared on a need-to-know basis.

Can I Get in Trouble for Making a Report?

The Company needs a culture where all associates are comfortable asking questions and raising concerns without fear of retaliation. Truthfully seeking advice, raising an honest concern or participating in an investigation in good faith cannot be used as the reason for threats, harassment or taking any adverse employment action, such as termination, demotion, suspension or loss of benefits.Although anyone who discloses their own misconduct may be penalized for their wrongful actions, no one will be punished for making honest disclosures about Code violations.

What if....

What if someone reports violations of our policy against sexual harassment, and it turns out that the caller made false allegations because he wanted to cause trouble for a co-worker whom he disliked?

Although there can be no retaliation against someone who reports a violation in good faith, this person acted in bad faith without a reasonable belief and could face discipline, even termination of employment.

What if I Prefer to Remain Anonymous?

Employees are able to submit a report on an anonymous and confidential basis through NAVEX Global/EthicsPoint and are therefore not required to divulge their names.

• NAVEX Global/EthicsPoint will assign a tracking number, so that you can check back to receive a response or provide more information.
• Please note, however, that anonymous claims are often difficult to investigate - and the Company will not tolerate retaliation for raising a good faith concern.

Some European privacy laws require that anonymous reports may only be made related to accounting, auditing or fraud related matters. If you live in one of these countries, you can report any other concern to your supervisor, another manager or any member of the Human Resources Department, the Legal Department or the Risk Management Committee.

4

Our Responsibility to the Company and to Each Other

What if I Do Not Follow the Code?

Violations of the letter or spirit of the Code, any applicable laws, rules, regulations or Company policies may result in disciplinary action, up to and including termination of employment and, in some cases, referral of the matter to law enforcement or regulatory authorities. Here are some examples of prohibited actions:

• Violations of the Code, Company policy or the law (or directing or urging others to do so);
• Not reporting a known or suspected violation of the Code, Company policy or the law;
• Failing to monitor the conduct of Acushnet associates, agents or vendors for whom you have oversight responsibility;
• Being uncooperative or untruthful during an investigation;
• Retaliating against others for raising or reporting a compliance concern;
• Intentionally or knowingly making a false compliance report; and
• Any other conduct inconsistent with a business environment of high integrity and commitment to compliance with the law.

What if I Think That the Code Conflicts with Local Law?

The Company understands and respects the diversity and many cultural differences in the countries in which we operate. Local laws and customs may require that Code implementation be flexible.

This Code and any policies mentioned here apply to the extent permitted by local laws and local subsidiary policies. However, if there is a difference between an individual Code provision and local law, custom or business practice, the more restrictive provision applies:

• If something permitted in our Code violates local law, we must follow local law;
• If a Code provision conflicts with a locally implemented policy, then the local policy applies; and
• If a local custom or business practice violates our Code, we must follow the Code.

If you believe that a Code provision conflicts with a local law or policy, you should discuss your concern with your manager or a member of the Human Resources Department, Legal Department or Risk Management Committee.

To be clear - no Acushnet associate shall be required to perform duties which are not permissible under local law or are contrary to locally implemented policies. Where local employment law grants protection against discipline, including dismissal, the local level of protection will be upheld by local management.

5

Our People

Our people make Acushnet successful and

everyone deserves to be treated fairly and with dignity.

Whether you design our products, make them, promote them, sell them, service them, account for them, or do any other task in support of any of these functions, every Acushnet associate makes a valuable contribution to the team.

The Company is committed to a workplace atmosphere of trust and respect, free from discrimination and harassment. We recruit, employ, evaluate and promote qualified people without regard to race, color, religion, sexual orientation, marital status, national origin, citizenship, sex, age, disability, veteran status, gender identity or expression, genetic information or any other basis prohibited by law.

Because diversity is a necessary and strategic goal for our business, we will create and support a workplace atmosphere with a diverse group of associates that respects those from different backgrounds.

• We will be respectful and professional at all times in the workplace, while on Company business or at other work related events or activities.
• We will work through disagreements or conflicts in a civil and constructive manner.
• We will not consider any legally protected characteristics in making employment related decisions. Our Company provides equal employment opportunity to all associates and applicants and makes employment-related decisions based on an individual's abilities, merits and legal right to work, not personal characteristics that are unrelated to the job.
• We will not sexually or otherwise harass anyone.
• We will not tolerate bullying or other hostile workplace behavior.
• We will always prioritize associates' health and safety.

This work environment promotes innovation and creativity and gives all associates the best opportunities to contribute to our Company's shared goals and collective success.

6