Arthrex is in material compliance with the California Transparency in Supply Chain Act of 2010 (S.B. 657. § 2, subd.(j).). Arthrex maintains a long-standing practice of complying with minimum-wage laws and requirements and does not use any form of forced, compulsory or child labor, and does not engage in the practice of slavery or human trafficking.
Arthrex expects all of its employees and suppliers to fully comply with this policy, and Arthrex takes all reasonably necessary steps to detect, prevent, investigate, and properly address violations of this policy.
- Engages in Verification
Arthrex is committed to fair labor practices within our supply chain. Our own internal auditors annually perform geographic evaluations of its supply chain to assess the risk of non-compliance in slavery, human trafficking and other human rights and labor issues.
- Conducts Audits of Suppliers
We monitor supplier behavior and compliance through our own internal auditors. Arthrex works aggressively each year to audit suppliers to exclude these types of labor and human rights abuses from our supply chain and ensuring human trafficking is not tainting our products. The intensity and frequency of these audits vary based on our geographical risk evaluations and also on the historical performance of a given manufacturing facility in our internal and external audits.
- Certification by Direct Suppliers
To ensure that our contractors and suppliers respect and enforce our company standards, Arthrex suppliers are required to sign a lengthy and comprehensive agreement which, along with a clause in the commercial agreement governing our contractual relationship with suppliers, requires them to comply with all applicable laws (which include those regarding child labor, slavery and human trafficking) and our Code of Conduct.
- Maintains Internal Accountability
Arthrex maintains internal accountability standards and procedures applicable to both employees and suppliers who may fail to meet company standards.
With regard to any issues identified in compliance audits of foreign manufacturers, a formal corrective action plan is developed with specific timeframes in which to correct the problem(s). Our internal audit team then visits these facilities on an unannounced basis to confirm adherence to the corrective action requirements. While we will typically provide 30-90 days for facilities to correct minor issues, we generally consider things such as forced/prison labor, slavery, human trafficking, child labor, physical/sexual abuse, and bribery of an auditor to be zero-tolerance issues requiring immediate remediation or withdrawal from the facility.
All Arthrex employees and suppliers receive regular training on all company policies, practices, and procedures designed to ensure that our supply chain is free of any type of coerced labor, including how to spot warning signs of potential human rights violations. All are required to sign their understanding and adherence to these policies, practices and procedures. We believe that a thorough understanding by all relevant individuals of the requirements of this policy is essential to mitigating risks associated with such critical issues as forced labor, slavery, human trafficking and child labor.