Responsible Supply Chain

We strive to conduct our activities in a manner that reflects our Mission and Code of Conduct – which includes being a good corporate citizen, dealing fairly in business, behaving ethically, supporting a safe and healthy workplace, doing business in an environmentally responsible manner, and complying with applicable law. We're committed to ensuring that our supply chain reflects our values and beliefs through our Responsible Supply Chain policies:

Supplier Code of Conduct

Our relationships with suppliers are based on lawful, efficient, and fair practices. Medtronic expects our suppliers and contractors to:

  • Abide by applicable laws, rules and regulations of the countries in which they operate
  • Uphold the human rights of workers and treat them with dignity and respect
  • Ensure a safe and healthy working environment
  • Practice social and environmental responsibility
  • Demonstrate the highest standards of business ethics

Medtronic reserves the right to discontinue business relationships with suppliers that fail to conduct business in a legal, responsible, and ethical manner.

Conflict Minerals Policy

As reflected in the Medtronic Mission, we strive to contribute to human welfare through the manufacture of products that alleviate pain, restore health, and extend life. We also seek to maintain good citizenship as a company. We are committed to ensuring that our supply chain reflects our values and beliefs, including adherence to principles of responsible sourcing of materials for our products

To finance their operations, armed groups responsible for civil discord and human rights violations in the Democratic Republic of Congo and nine adjoining countries operate mines to extract gold and ores that are processed into tin, tungsten and tantalum, which are commonly called “Conflict Minerals.” Conflict Minerals can make their way into the supply chains for products manufactured across the globe. The U.S. Securities and Exchange Commission (SEC) has adopted rules to implement reporting and disclosure requirements related to Conflict Minerals as part of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank Act”). Medtronic supports the goals and objectives of Section 1502 of the Dodd-Frank Act that requires public companies to determine the sourcing of tin, tungsten, tantalum, and gold used in their products and to file an annual report disclosing any such use. As part of our commitment to responsible sourcing and human welfare, the Company has adopted Medtronic Conflict Minerals Policy.

If you have specific questions regarding Conflict Minerals, please contact us at

Support of California Transparency in Supply Chains Act

Medtronic is committed to improving the quality of life of our supply chain’s manufacturing workforce. On Jan. 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) went into effect, requiring retailers and manufactures above a certain size doing business in California to disclose measures used to track possible slavery and human trafficking in their supply chains. The disclosure is aimed at providing information to consumers, allowing them to make better, more informed choices about the products they buy and the companies they support.

In addition, Medtronic’s EICC Code of Conduct supplier requirement addresses freely chosen employment, as well as numerous other fair labor practices. Medtronic continues to deepen the evaluation and assessment of its supply chain’s responsible sourcing practices. One of our five pillars of Corporate Citizenship is Responsibility in the Marketplace, which includes ensuring that we follow and enforce best practices in our supply chain.

Learn more about Medtronic’s Corporate Citizenship.

Medtronic Code of Conduct

We require all employees and agents to comply with Medtronic’s global Code of Conduct. We investigate alleged violations of the Code of Conduct and take the appropriate action, up to and including termination for employees, and termination of agreements with contractors.

We train employees who work directly with supply chain management on awareness of how their decisions can potentially impact factory working conditions and equip them with the necessary knowledge to reinforce to suppliers the importance of positive factory labor practices. This is fundamental to fully integrating labor compliance and social responsibility into all purchasing decisions, and building a socially and environmentally responsible supply chain.

Policy on Gifts

Medtronic employees may not accept gifts from persons or entities that deal with the Company if the gift is more than modest in value, or if acceptance of the gift could create the appearance of a conflict of interest.