Arthrex, Inc.
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Global Supply Chain Disclosure


Arthrex is committed to doing business ethically and responsibly and will only work with companies that share that commitment.

The California Transparency in Supply Chains Act and the UK Modern Slavery Act require companies doing business in those jurisdictions to disclose their efforts to eradicate slavery and human trafficking from their supply chains. Arthrex enthusiastically joins the fight to end forced labor and disclose the efforts we have undertaken to ensure that our supply chain is free from such abhorrent practices.    

As part of our initiative to identify and mitigate risks, Arthrex has taken the following steps and is continuously working to further improve our policies and practices to ensure materials and services provided to Arthrex are procured only from suppliers who share this same level of commitment.

Policies:

In 2019, Arthrex updated its Global Code of Conduct, strengthening its commitment to corporate responsibility and giving clear guidance on key expectations including human rights and modern slavery. The updated Global Code of Conduct was launched at the end of 2019 and is available in 18 languages. Arthrex also provides several communication channels for reporting concerns or violations in good faith, including but not limited to the Arthrex Ethics Helpline.

In 2020, Arthrex adopted the Global Policy on Human Rights that prohibits the use of slavery and human trafficking in Arthrex facilities and by suppliers in Arthrex’s supply chain.

As described below, Arthrex takes the following steps to manage supply chain relationships responsibly:

Verification:

Arthrex is committed to fair labor practices within its supply chain and expects its suppliers to meet these expectations. Arthrex uses a third party to investigate the background of all potential new suppliers to assess the risk of noncompliance with laws, including those related to slavery, human trafficking, and other human rights.

Audits:

Arthrex monitors supplier behavior and compliance through announced routine audits. Our suppliers are reviewed on implementation of policies prohibiting all forms of human trafficking and forced labor. The selection, scope and frequency of these audits vary based on various risk factors.

Certification:

To ensure our suppliers respect and enforce our company standards, Arthrex suppliers are required to sign a Master Supply Agreement that mandates compliance with all applicable laws in their respective countries (including but not limited to laws regarding slavery, human trafficking, and other human rights) as well as the Arthrex Code of Conduct. The selection and scope of suppliers required to sign a Master Supply Agreement varies based on a range of risk factors. Additionally, Arthrex’s Purchase Order Terms and Conditions require suppliers to certify that materials or items supplied to Arthrex were not manufactured from or with child, forced, or prison labor.

Accountability:

Arthrex maintains internal accountability standards and procedures applicable to both employees and suppliers who fail to meet company standards. Where noncompliance is identified, a corrective action plan, up to and including termination, is put in place.

Training:

All employees with direct responsibility for supply chain management undergo specific training focused on identification and risk mitigation of slavery, human trafficking, and other human rights within the supply chain.

 

Signed by:

 

Peter Jensen

VP, Global Risk Management & Compliance

 

Paul Bosworth

General Manager, UK

 

This disclosure is updated annually and was last updated on August 18, 2020.