SUPPLIER STANDARDS AND POLICIES

Our Commitment

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, upholding human rights, supporting a safe and healthy workplace, doing business in an environmentally responsible manner, and complying with applicable law. We are committed to ensuring that our supply chain reflects our values and beliefs through our policies, procedures, and best practices.

Medtronic Code of Conduct

We require all employees and agents to comply with the Medtronic 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 in supply management on awareness of how their decisions can potentially impact factory working conditions and equip them with the necessary knowledge of 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.

Global Supplier Standards

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.

Translated versions of the Global Supplier Standards are available below.

Global Human Rights and Labor Standards Policy

Medtronic aims to be a positive social presence in every community where we work. We promote basic human rights by following applicable local labor laws. We do not allow child or forced labor, and we strive to ensure that Medtronic’s vendors and suppliers follow these same standards. We also follow all applicable wage and hour laws, including minimum wages, overtime, and maximum hour rules.

Read and download our Global Human Rights Program Report

LEARN ABOUT OUR POLICY

• GLOBAL HUMAN RIGHTS AND LABOR STANDARDS POLICY
• GLOBALE RICHTLINIE FÜR MENSCHENRECHTE UND ARBEITSSTANDARDS
• POLÍTICA GLOBAL DE ESTÁNDARES LABORALES Y DERECHOS HUMANOS
• POLITIQUE MONDIALE RELATIVE AUX DROITS DE L'HOMME ET AUX NORMES DE TRAVAIL
• POLITIQUE MONDIALE RELATIVE AUX DROITS DE L'HOMME ET AUX NORMES DE TRAVAIL
• POLITICA GLOBALE SUI DIRITTI UMANI E GLI STANDARD IN TEMA DI LAVORO
• 人権・労働基準に関するグローバル方針
• 글로벌 인권 및 근로 기준 정책
• BELEID WERELDWIJDE MENSENRECHTEN EN ARBEIDSNORMEN
• POLÍTICA GLOBAL DE NORMAS TRABALHISTAS E DIREITOS HUMANOS
• 全球人权和劳工标准政策
• นโยบายสิทธิมนุษยชนทั่วโลกและมาตรฐานแรงงานที่นำไปใช้ทั่วโลก

Click here for more information on Medtronic's commitment to human rights and our Human Rights Framework

RESPONSIBLE 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 Responsible Minerals Policy.

If you have specific questions regarding Conflict Minerals, please contact us at rs.conflictminerals@medtronic.com.

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.

Specific questions related to information on this page can be addressed to rs.responsiblesupplymanagement@medtronic.com.