LPGA GENDER POLICY FOR COMPETITION ELIGIBILITY

(Effective January 1, 2025)

1. INTRODUCTION

For more than seven decades, the LPGA has been a leader in championing diversity and inclusion, both on and off the golf course. From our founding members to our current initiatives, we have continuously strived to create a welcoming environment where everyone, regardless of background or identity, feels empowered to participate in the sport. As the global leader in women’s golf, the LPGA is committed to using our unique platform to empower, inspire, and advance opportunities for girls and women, and our commitment to diversity, equity, and inclusion remains integral to who we are and what we do.

At the same time, the LPGA represents the pinnacle of women’s golf where the best female players in the world compete to earn a living, and it is critical that the LPGA ensures in our rules and policies that the playing field is fair and level for the female competing in our elite events. In consulting with top experts in the fields of medicine, science, sport physiology and golf performance, we have been advised that a Player’s exposure to male puberty provides physical advantages that are beneficial to golf performance compared to Players who have not had such exposure.

The LPGA has updated our Gender Policy for Competition Eligibility to uphold the fairness and integrity of our elite competitions while providing an inclusive environment for the broader LPGA community, which remains accessible to all women for non-elite events and activities. Guided by medical, scientific, legal expertise, and consultation with our members, the Policy seeks to balance inclusivity with ensuring competitive integrity at the highest levels of play. There is a place for all women to participate in golf through the broader LPGA community. This principle guided the creation of our Policy and will continue to guide our future.

For purposes of this Policy, “LPGA” means individually and collectively the LPGA Tour, Epson Tour, LET, LETAS, LPGA Professionals and Girls Golf. This Policy does not apply to the LPGA Amateurs Association. The Gender Policy for LPGA Amateurs Association can be accessed through the registration portal for the applicable event.

All terms defined within this Policy shall have the meanings set forth in Appendix I attached hereto or as otherwise specified herein, unless the context requires a different interpretation.

2. GENERAL APPLICATION OF THIS POLICY

2.1. LPGA respects the right of all individuals to adopt a gender identity different than their Sex Assigned at Birth. Except as provided in Section 3 below as to Elite Events, individuals may participate in LPGA activities in accordance with their gender identity without limitation, including governance, employment, participation in LPGA Professionals training and education programs and Girls Golf.

2.2. The dignity of every individual must be respected. All forms of abuse or harassment are prohibited. No stigmatization or improper discrimination on the basis of gender identity will be tolerated. In particular, persecution or other campaigns against a person simply on the basis of their gender identity is unacceptable. Any such conduct will be considered a serious breach of the applicable Code of Conduct.

2.3. No Player will be forced to undergo any medical treatment under this Policy. It is the Player’s responsibility, in close consultation with their medical team, to decide on the advisability of proceeding with any treatment.

2.4. This Policy operates without prejudice to the other eligibility requirements that are applicable to Players under other LPGA policies and regulations, including without limitation the LPGA Anti-Doping Program. Nothing in this Policy permits, excuses, or justifies non-compliance with any of those requirements, including without limitation any requirement for a Player to obtain a therapeutic use exemption for the use of substances on the LPGA List of Prohibited Substances and Methods.

3. APPLICATION OF THIS POLICY ESTABLISHING ELIGIBILITY TO PARTICIPATE IN SPECIFIC LPGA EVENTS

3.1. The Gender Eligibility Criteria set forth in Section 4 below, apply to any Player who seeks to participate in the following tournaments (individually and collectively “Section 3.1 Elite Events”).

A. LPGA Tour (all events)

B. Epson Tour (all events).

C. Ladies European Tour (all events).

D. Ladies European Tour Access Series (all events).

E. LPGA Tour, Ladies European Tour, Epson Tour and Ladies European Tour Access Series qualifying events (for example, local qualifiers and “Q Series”).

F. LPGA Professionals Division: Championship.

G. LPGA Girls Golf: LPGA World Golf Championship.

H. Any other event specifically designated for inclusion in this list by the LPGA.

4. GENDER ELIGIBILITY CRITERIA

4.1. Subject to Section 4.3 below, Players whose Sex Assigned at Birth is female shall be eligible to participate in all LPGA activities and events without regard to their gender identity.

4.2. To be eligible to compete in Section 3.1 Elite Events, a Player whose Sex Assigned at Birth is male, must establish to the satisfaction of the Medical Manager and Expert Panel that they have not experienced any part of male puberty either Beyond Tanner Stage 2 or after age 12 (whichever comes first)[1]. In addition, they must establish to the satisfaction of the Medical Manager and Expert Panel:

4.2.1. Since receiving gender reassignment treatment, they must have continuously maintained the concentration of testosterone in their serum below 2.5 nmol/L (“Testosterone Limit”).

4.2.2. They must continue to maintain the concentration of testosterone in their serum below the Testosterone Limit (i.e., whether they are in competition or out of competition) for so long as they wish to retain eligibility to compete in Section 3.1 Elite Events.

4.3. To be eligible to compete in any Section 3.1 Elite Events, a Player whose Sex Assigned at Birth is female, but who has used any growth or muscle promoting substance or method identified on the LPGA List of Prohibited Substances or Methods in connection with any reassignment treatment, prescribed by a physician or otherwise, must demonstrate to the satisfaction of the Expert Panel that they do not have any continuing performance enhancing benefit from such use.

5. GENDER ELIGIBILITY APPLICATION

5.1. Any Player who is subject to the Gender Eligibility Criteria described in Section 4.2 or Section 4.3 shall file a Gender Eligibility Application with the LPGA Medical Manager and LPGA General Counsel, no later than 60 days prior to an Elite Event which they have qualified for or may be eligible to qualify for. To request the Gender Eligibility Application, please email Compliance@LPGA.com. The application must include the following:

5.1.1. A comprehensive medical history, including details of:

A. any reassignment surgeries or pharmacological treatment the Player has undertaken, including the date(s) of any such procedures and what Tanner Stage the Player was in at the time of the surgery and/or pharmacological treatment;

B. any other relevant treatment the Player has received (including pre- or post-reassignment treatment), including the dates, timing, dosage, and frequency of such treatment; and

C. the results of any pre- or post-reassignment monitoring.

5.2. A Player subject to Section 4.3 must provide a declaration and other evidence satisfactory to the Medical Manager and the Expert Panel demonstrating that the Player’s use of any growth or muscle promoting substance or method identified on the LPGA List of Prohibited Substances or Methods in connection with gender reassignment treatment, prescribed by a physician or otherwise, has not resulted in any continuing performance enhancing benefit to the Player.

5.3. The Player is responsible for ensuring that the information provided is accurate and complete, and that nothing relevant to the Expert Panel's assessment of the case is withheld. The Player must also provide the appropriate consents and waivers (in a form satisfactory to the Medical Manager) to enable the Player’s physicians to disclose to the Medical Manager and the Expert Panel any information that the Medical Manager or Expert Panel deems necessary for its assessment.

5.4. After communicating with the Player and/or the Player's physicians to address any deficiencies, the Medical Manager will submit the anonymized Gender Eligibility Application to the Expert Panel. The submission will outline the detailed steps proposed by the Medical Manager for the ongoing monitoring of the Player’s serum testosterone levels. The Medical Manager will revise these proposed steps as needed to align with the Expert Panel’s assessment and recommendations.

5.5. Any Player who has not submitted a Gender Eligibility Application pursuant to this Section shall have no standing to challenge the enforceability of this Policy. By submitting a Gender Eligibility Application, the Player agrees to be bound by all terms of this Policy, specifically including, but not limited to Section 10 Dispute Resolutions and Section 14 Limitations of Liability.

6. INVESTIGATIONS

6.1. Provided that the Medical Manager is acting in good faith and on reasonable grounds based on reliable information or reliable sources, the Medical Manager may investigate whether a Player who is competing, or seeks to compete, in a Section 3.1 Elite Events may be a Player to whom the Gender Eligibility Criteria in Section 4.2 or Section 4.3 applies. No third party shall have the right to initiate or participate in any such investigation.

6.2. The Medical Manager may also investigate, at any time:

6.2.1. whether (because of a subsequent change in circumstances, subsequent learning, or experience, or otherwise) it is necessary to require a Player who has previously been determined to satisfy the Gender Eligibility Criteria to undergo further assessment by the Expert Panel to determine whether they still satisfy those criteria; and/or

6.2.2. any circumstances that indicate potential non-compliance by a Player with this Policy.

6.3. The Player in question must cooperate fully and in good faith with the investigation by the Medical Manager and any subsequent assessment by the Expert Panel, including by providing serum and/or urine samples upon request for analysis, and/or submitting to medical examination.

6.4. Where the Player does not cooperate as required under this Section 6, or otherwise as required by this Policy, or where otherwise necessary to safeguard the fairness and/or integrity of competition, the LPGA may provisionally suspend the Player from competing in Section 3.1 Elite Events, pending resolution of the matter. Where such provisional suspension is imposed, all reasonable endeavors must be used to complete the investigation and assessment as expeditiously as possible. Any such provisional suspension may be appealed in accordance with Section 10 of this Policy.

6.5. Where the Medical Manager concludes following an investigation that the Gender Eligibility Criteria set forth in Section 4.2 or Section 4.3 apply to a Player, the Medical Manager will notify the Player that they will be required to submit a Gender Eligibility Application and provide the information set out in those sections so that their case may be assessed.

7. EXPERT PANEL ASSESSMENT

7.1. In each case brought to the Expert Panel, the Expert Panel Chair shall appoint three (3) or more Expert Panel members to manage and make decisions for the Expert Panel in that case.

7.2. It shall be the Player’s burden to establish to the satisfaction of the Expert Panel that the Gender Eligibility Criteria set forth in this Policy have been and will continue to be satisfied.

7.3. The Expert Panel will assess cases referred by the Medical Manager to determine whether the Gender Eligibility Criteria have been satisfied or, if not, what additional steps the Player must take to satisfy the criteria. The Expert Panel may conduct any enquiries or investigations it considers necessary to carry out the assessment accurately and effectively, including requesting further information from the Player or the Player's physician and/or obtaining additional expert opinions.

7.4. If the Expert Panel identifies concerns regarding the adequacy of any of the information provided by or on behalf of the Player, it will provide the Player with a fair opportunity to address those concerns before reaching a final decision.

7.5. Once it has completed its assessment, the Expert Panel will issue its decision by writing to the Medical Manager, who will then forward it to the Player (with a copy to the Player's physician, if applicable).

7.5.1. If the Expert Panel concludes the evidence provided is insufficient to meet the Player’s burden of demonstrating compliance with the Gender Eligibility Criteria, it must provide a written explanation of its decision. Where applicable, the explanation will also outline any additional steps the Player must take to satisfy the criteria, such as monitoring; reporting; further reviews.

7.5.2. If the Expert Panel determines that the Gender Eligibility Criteria have been met, the Medical Manager will issue a written certification of that Player's eligibility to compete in Section 3.1 Elite Events. That eligibility will remain conditional upon the Player continuing to satisfy the Gender Eligibility Criteria.

7.6. The Expert Panel's decision will be final and binding on all parties. It may only be challenged by way of appeal in accordance with Section 8 of this Policy.

7.7. The Expert Panel may adopt guidelines further describing the technical aspects of its assessment process.

8. CONTINUING COMPLIANCE

8.1. A Player subject to Section 4.2 of the Gender Eligibility Criteria will be solely responsible for maintaining the concentration of testosterone in their serum at less than the Testosterone Limit for as long as they wish to remain eligible to compete in Section 3.1 Elite Events.

8.2. The Medical Manager or Expert Panel may specify particular means of demonstrating such continuing compliance. In any event, the Player must produce, on request, evidence satisfactory to the Medical Manager of such continuing compliance. In particular, except where the Player described in Section 4.2 can prove to the satisfaction of the Expert Panel that they have had a gonadectomy or other procedure that will have necessarily and permanently suppressed their testosterone below the Testosterone Limit, the Medical Manager:

8.2.1. may require the Player to provide ongoing evidence of the concentration of testosterone in their serum, such as laboratory reports obtained by their personal physician of the results of analysis of samples collected periodically from the Player;

8.2.2. may monitor the concentration of testosterone in the Player’s system, including by having samples collected from the Player and analyzed for relevant evidence;

8.2.3. may consult with the Expert Panel Chair at any stage during this process as the Medical Manager considers necessary; and

8.2.4. may refer the Player described in Section 4.2 back to the Expert Panel for further assessment.

8.3. To facilitate the Medical Manager’s monitoring of the testosterone levels of a Player who is subject to Section 4.2 of this Policy, the Player:

8.3.1. must submit to collection of samples of their serum and/or urine on demand by a service provider engaged by the Medical Manager, in accordance with sample collection procedures prescribed by the Medical Manager to safeguard the identity and integrity of the samples and consents to the Medical Manager having those samples analyzed to assess the Player’s compliance with the requirements of this Policy;

8.3.2. consents to the Medical Manager using data from samples collected under the LPGA Anti-Doping Program to assess the Player’s compliance with the requirements of this Policy; and

8.3.3. agrees to advise the Medical Manager of the results of analysis of samples collected from the Player by others under applicable anti-doping rules (or, if they do not have that information, agrees to do everything in their power to ensure that the person holding that information provides it to the Medical Manager) for purposes of assessing their compliance with the requirements of this Policy.

8.4. If a Player who has previously been declared eligible to compete in Section 3.1 Elite Events:

8.4.1. refuses or fails without compelling justification to comply with one or more of the requirements of the Policy; or

8.4.2. is subject to Section 4.2 of this Policy and is found (whether by sample analysis or otherwise) to have failed to keep the concentration of testosterone in their serum below the Testosterone Limit; then:

A. where the Player is able to satisfy the Expert Panel on the balance of probabilities that their failure to keep the concentration of testosterone in their serum below the Testosterone Limit was unintentional, the Player will be ineligible to compete in any Section 3.1 Elite Events for such period (if any) as the Expert Panel shall consider necessary to protect fair competition; and

B. where the Player is not able to satisfy the Expert Panel on the balance of probabilities that their failure to keep the concentration of testosterone in their serum below the Testosterone Limit was unintentional, the Player will be ineligible to compete in Section 3.1 Elite Events for the same period as the period of ineligibility that they would have received for intentional use of an anabolic steroid under the LPGA Anti-Doping Program in force at the relevant time.

The Player will be given a reasonable opportunity to provide any explanations or comments they see fit before any results are disqualified or any period of ineligibility is imposed pursuant to Section 6.4 of this Policy.

8.5. The Medical Manager may require a Player subject to Section 4.3 to provide continuing assurance that they have not used and are not using a growth or muscle promoting substance or method identified on the LPGA List of Prohibited Substances or Methods. To facilitate the Medical Manager’s monitoring of this commitment, the Player agrees to consent and submit to the testing requirements set forth in Sections 8.3.

9. DISCIPLINARY PROCEEDINGS

9.1. Where a Player competes in an Elite Event for which they have not satisfied the Gender Eligibility Criteria set out in this Policy or violates their obligations set forth in Section 8 of this Policy, the LPGA Tour Commissioner (or their nominee), if they consider it necessary to do so to maintain the integrity of Section 3.1 Elite Events, may provisionally suspend the Player, and/or disqualify the individual results obtained by the Player, with all resulting consequences, including but not limited to forfeiture of any ranking points, prize money, and other status or items awarded to the Player based on those results.

9.2. Where a Covered Person has been complicit in a breach of or non-compliance with this Policy by a Player, such breach of this Policy shall be considered a Code of Conduct breach and will accordingly be subject to investigation and disciplinary action pursuant to the applicable Code of Conduct. In such Code of Conduct disciplinary proceedings, the validity of this Policy or of any decision made under this Policy may not be challenged. Instead, such challenge may only be brought by way of challenge or appeal in accordance with Section 10 of this Policy.

10. DISPUTE RESOLUTIONS

10.1. Excluding the disciplinary matters referenced in Section 9.2 of this Policy (which will be addressed as set out in the applicable Code of Conduct), any dispute arising between the LPGA and a Player in connection with this Policy will be subject to the exclusive jurisdiction of the CAS. In particular, the validity, legality, and/or proper interpretation and application of this Policy may only be challenged (a) by way of ordinary proceedings filed before the CAS; and/or (b) as part of an appeal to the CAS made pursuant to Section 10.2 of this Policy.

10.2. The following decisions (and only the following decisions) made under this Policy may be appealed by the Player who is the subject of the decision to the CAS in accordance with this Section 10 of this Policy, by filing a Statement of Appeal with the CAS and with LPGA (as the respondent to the appeal) within thirty (30) days of the date of receipt of the written reasons for the decision:

10.2.1. a decision that the Player is subject to the Gender Eligibility Criteria set forth in Section 4.2 or Section 4.3;

10.2.2. a decision that the Player does not comply with any of the requirements of this Policy;

10.2.3. a decision to suspend a Player provisionally from competition; and

10.2.4. a decision of this Policy to disqualify results and/or to impose a period of ineligibility.

10.3. Any such challenge or appeal will be conducted in the English language and will be governed by this Policy, and the other applicable policies and regulations of the LPGA, with the laws of the state of Florida applying subsidiarily. The CAS will hear and determine the challenge or appeal definitively in accordance with the CAS Code of Sports-Related Arbitration, provided that (a) in the event of any conflict between the aforementioned governing instruments and laws on the one hand and the CAS Code of Sports Related Arbitration on the other hand, the governing instruments and laws will take precedence; and (b) in any appeal the Player will have fifteen (15) days from the filing of the Statement of Appeal to file their Appeal Brief, and the LPGA will have thirty (30) days from its receipt of the Appeal Brief to file its Answer. Unless otherwise ordered by CAS or agreed by the parties, the hearing on the merits will take place in the city where the LPGA has its headquarters. Pending determination of the challenge or appeal, the Policy and the decision under appeal will remain in full force and effect, unless the CAS orders otherwise.

10.4. The decision of the CAS on the merits of the challenge or appeal will be final and binding on all parties, and no right of appeal or other challenge will lie from that decision on any ground, except as set out in Chapter 12 of the Swiss Federal Code on Private International Law.

11. CONFIDENTIALITY

11.1. All Gender Eligibility Applications, cases and claims arising under this Policy, and in particular all information relating to a Player that is provided to LPGA under this Policy, and all results of examinations and assessments conducted under this Policy, must be maintained in strict confidence at all times. All medical information and data relating to a Player will be treated as sensitive personal information, and the Medical Manager must ensure that it is processed as such in accordance with applicable data protection and privacy laws. Such information and data may not be used for any purpose that is not contemplated in this Policy and may not be disclosed to any third party except as is strictly necessary for the effective application and enforcement of this Policy or as is required by law. For purposes of mutual recognition, LPGA may advise another golf organization whether or not a Player has been approved under this Policy to compete in Section 3.1 Elite Events. However, the underlying medical information will not be shared with other organizations without the Player’s consent.

11.2. LPGA will not comment publicly on the specific facts of a case arising under this Policy (as opposed to general descriptions of the process and science involved) except in response to public comments made by the Player or the Player’s representatives.

11.3. Each member of the Expert Panel must sign an appropriate conflict of interest declaration and confidentiality agreement related to their role as a member of the Expert Panel.

12. COSTS

12.1. LPGA will bear the costs of assessment and compliance of the Player under this Policy (including the standing costs of the Expert Panel and all costs of the doctors and experts involved by the Expert Panel in such assessment), as well as the costs of the LPGA or its representatives collecting samples from the Player to monitor their compliance with the requirements of this Policy.

12.2. The Player will bear the costs of their personal physician(s) and of any treatment prescribed for them by their personal physician(s), including any treatment required to satisfy the requirements of this Policy, as well as any other costs of demonstrating compliance with this Policy that are not paid by the LPGA pursuant to Section 12.1 of this Policy.

13. MUTUAL RECOGNITION

13.1. LPGA may recognize and give effect to the eligibility decision of other major golf organizations in relation to that Player, provided that the eligibility decision criteria and the regulations of that other organization are consistent with this Policy. Any eligibility so afforded shall be subject to ongoing compliance by the Player with the requirements of this Policy.

14. LIMITATION OF LIABILITY

14.1. In no circumstances will LPGA, any member of the Expert Panel, or any of LPGA’s employees, officers, agents, representatives, and other persons involved in the application and/or enforcement of this Policy be liable in any way to any person in relation to acts done or omitted to be done in good faith in connection with this Policy.

14.2. Each case will be addressed as quickly as is reasonably practicable in all circumstances. However, in no circumstance will LPGA or the Medical Manager or any member of the Expert Panel be liable for any detriment allegedly suffered by the Player in question or anyone else as a result of the length of time taken to complete the investigation/assessment of their case.

15. UNFORESEEN ISSUES

15.1. If an issue arises that is not otherwise addressed in this Policy, LPGA reserves the right to address the issue in a manner which is consistent with the principles set forth in Section 1 of this Policy.

16. FUTURE POLICY CHANGES

16.1. LPGA will continue to monitor medical, scientific and relevant sport performance data and research as well as the practical aspects of this Policy. LPGA reserves the right to amend this Policy in its sole discretion at any time with or without notice.

16.2. At such time as any amendment to this Policy goes into effect, it shall immediately become the basis on which any future or current Player’s eligibility to participate will be assessed, regardless of the Player’s eligibility status prior to the new or amended Policy’s effective date.

APPENDIX I

DEFINITIONS

1. “CAS” The Court of Arbitration for Sports.

2. “Code of Conduct” The code of conduct for LPGA, as applicable.

2.1. LET Tour Code of Ethics and Standards of Conduct

2.2. Girls Golf Code of Conduct

2.3. Epson Tour Code of Ethics and Standards of Conduct

2.4. Girls Golf Operations Manual – Code of Conduct

2.5. LPGA Professionals – Code of Ethics and Standards of Conduct

2.6. LPGA Tour Code of Ethics and Standards of Conduct

3. “Covered Person” Any person who has agreed to be bound by the rules of the LPGA or any applicable Code of Conduct.

4. “Elite Event” Those events described in Section 3.1 of the Policy.

5. “Expert Panel” The individuals appointed by the LPGA Commissioner (or their designee), including the Expert Panel Chair, with preference for individuals with experience related to transgender health, gender affirming treatment, the mitigation of physiological effects resulting from male puberty, endocrinology, sports physiology and performance related to golf.

6. “Gender Eligibility Criteria” The criteria set forth in Section 4 of this Policy.

7. “Medical Manager” A medical doctor appointed by the LPGA Commissioner (or their designee) to perform the administrative and decision-making functions assigned to the Medical Manager under this Policy.

8. “Policy” This LPGA Gender Policy for Competition Eligibility.

9. “Sex Assigned at Birth” This means the male or female designation that healthcare professionals ascribe to infants based on genitalia and is marked on their birth records. This is to be understood as the initial assignment regardless of any subsequent changes to the birth certificate.

10. “Tanner Stages” The medical analysis that denotes the five stages of puberty during which individuals develop secondary sex characteristics. Tanner Stage 2 denotes the onset of puberty. The normal time of onset of puberty ranges from 8-13 years old in females, and 9-14 years old in males. (“Beyond Tanner Stage 2” as used in Section 4.2 means that the Player has not yet started Tanner Stage 3.)