CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT STATEMENT

The California Transparency in Supply Chains Act of 2010 requires certain businesses to provide public disclosures regarding efforts to eradicate slavery and human trafficking from their supply chains.

Medtronic strives to conduct its activities in a manner that reflects its 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're committed to ensuring that our suppliers reflect our values and beliefs by conducting business in ways that are consistent with Medtronic’s applicable policies, practices, and Global Human Rights Framework.

Consistent with the California Transparency in Supply Chains Act, Medtronic shares the following illustrative efforts.

• Verifying product suppliers by evaluating and addressing risks of human trafficking and slavery through the following mechanisms:
  • Publishing the Global Supplier Standards that set expectations for Medtronic suppliers’ social, environmental and business conduct.
  • Adopting the Global Human Rights and Labor Standards Policy that prohibits the use of slavery and human trafficking in Medtronic and supplier facilities.
  • Adopting the Global Anti-Human Trafficking and Forced Labor Policy that reinforces the company’s commitment to prohibit the use of human trafficking, slavery, and forced labor in Medtronic and supplier facilities.  (Policy available in Global Human Rights Program Report)
  • Implementing multiple platforms to aggregate data streams across our complex supply chain – for the product lifecycle: from raw materials to final destination – to identify and mitigate supply risks, including:
    • Mapping our critical first tier and sub-tier suppliers across our supply chain
    • Developing supplier risk scorecards based on numerous risk factors (e.g., strategic importance, location, material, connections, media-reporting)
    • Integrating ongoing monitoring with real-time updates from global human rights / forced labor watchlists
    • Developing predictive insights and risk analytics across our supplier network
  • Maintaining Medtronic’s Supplier Sustainability Assessment program to monitor and verify certain suppliers’ compliance with Medtronic Standards through desktop and on-site audits.
  • Clearly outlining Medtronic’s human rights and supply chain responsibility expectations and objectives within the annual Integrated Performance Report.
  • Identifying, assessing, and tracking human rights related risks within Medtronic’s Enterprise Risk Management (ERM) program.

• Requiring certain suppliers to certify that they comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business through, for example:
  • Incorporating social responsibility and environmental criteria in its supplier selection and management processes. The Global Supplier Standards, for instance, have been included in purchase order terms and conditions as well as certain supplier agreements.
  • Requiring certain suppliers to adhere to all applicable laws relating to labor, environmental, health / safety and ethics, and by way of example and without limitation, Medtronic’s Code of Conduct, Global Human Rights and Labor Standards Policy.
  • Requiring identified high-risk suppliers to certify that no part of Medtronic’s supply chain (including direct, indirect, first tier, sub-tier) uses forced labor in the sourcing, manufacturing, packaging, and / or shipping of Medtronic products. 

• Maintaining internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking through, for example:
  • Establishing the Global Human Rights Program that is aligned with Medtronic’s Mission and in response to issues that are material to the company and its key stakeholders. The program addresses human rights and labor standards issues, risks, and performance in Medtronic’s operations. 
  • Establishing the cross-functional Human Rights Supplier Issues Panel, which serves as an executive forum for addressing human rights and labor standards issues, risks and performance in company operations and through certain suppliers.
  • Requiring all employees to adhere to all applicable laws relating to labor, environmental, health / safety and ethics, and by way of example and without limitation, Medtronic’s Code of Conduct, Global Human Rights and Labor Standards Policy.

• Requiring comprehensive Responsible Supply Management awareness training for employees with direct responsibilities for supplier selection and management. This training includes, for example:
  • An overview of potential human rights and labor standards issues
  • The details of the Global Supplier Standards and supplier compliance requirements
  • Supplier selection and management best practices

September 2023