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Arthrex is a global leader in new product development and medical education in orthopedics and we are committed to one mission: Helping Surgeons Treat Their Patients Better. Arthrex is headquartered in Naples, Florida, with subsidiaries around the world. Approximately 85% of Arthrex’s products are made in the United States. The top six countries from which goods, services or materials are sourced outside the U.S. are: Germany, Switzerland, Israel, Netherlands, Italy and Taiwan. Arthrex manufacturing sites are located in countries which are not considered high-risk jurisdictions by the Global Slavery Index. Our supply chain consists of direct and indirect suppliers. 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.

Policies:

As part of an ongoing initiative to identify and mitigate risks, Arthrex continuously works to further improve its policies and practices to ensure materials and services provided to Arthrex are procured only from suppliers who share this same level of commitment.

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. 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.

Arthrex also provides several communication channels for reporting concerns or violations in good faith, including but not limited to the Arthrex Ethics Helpline.

Governance:

Good corporate governance is fundamental to Arthrex activities. Arthrex maintains a comprehensive Global Risk Management & Compliance program to prevent and detect violations of the Global Code of Conduct, company policies and applicable laws and regulations, including those which relate to Human Rights violations. Arthrex has a process in place for entering, managing and investigating reports received through the Arthrex Ethics Helpline. The Global Risk & Compliance Committee oversees any reportable events, potential risk areas and risk management activities and monitors the effectiveness of the Global Risk Management & Compliance program.   

Verification/Due Diligence:

Arthrex is committed to fair labor practices within its supply chain and expects its suppliers to meet these expectations. As such, the company conducts supplier assessments to assess risk related to slavery, human trafficking and other human rights, and to identify areas for suppliers to implement effective controls. In addition, suppliers are required to provide a Certificate of Origin positively affirming the country of origin of all products sold to Arthrex. The company continues to enhance due diligence related to suppliers by integrating controls into the existing Third-Party Risk Management process. Since 2022, Arthrex uses a third party to conduct due diligence on existing suppliers and to investigate the background of potential new suppliers to assess the risk of noncompliance with laws, including those related to slavery, human trafficking and other human rights. In addition, Arthrex implemented a third-party risk management tool to provide information on current supplier risks, as well as regular newsfeed updates on labor practices and other human rights risks.

Audits:

Arthrex monitors supplier behavior and compliance through announced routine audits to improve visibility, leverage and oversight of our supply chain. As part of these audits our suppliers are reviewed on implementation of policies prohibiting all forms of human trafficking and forced labor. The company currently focuses its efforts on high-risk suppliers, determined by various risk factors including but not limited to supplier location and propensity for utilization of slavery, human trafficking or forced labor.

Certification:

To ensure our suppliers respect and enforce company standards, all Arthrex suppliers are bound by contractual terms that mandate compliance with the Arthrex Code of Conduct, and all applicable laws and regulations in their respective countries, including but not limited to, the prohibition against slavery, human trafficking and any other practice that violates human rights as defined within the United Nations Universal Declaration of Human Rights. A supplier’s failure to provide certification affirming compliance with the prohibition against slavery, human trafficking, and other human rights violations may result in corrective action up to and including termination of the business relationship. In addition, the company mandates its suppliers warrant that products sold to Arthrex do not contain conflict minerals as such term is defined in the “Dodd-Frank Wall Street Reform and Consumer Protection Act,” or any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo (DRC) or adjoining countries.

Accountability:

Arthrex maintains internal accountability standards and procedures applicable to both employees and suppliers who fail to meet company standards. The company provides several channels for employees and third parties to report potential non-compliance and has procedures in place for investigating, substantiating and remediating reports of potential human rights violations. Reports can be provided confidentially or anonymously so that they can be properly investigated and remedied without fear of retaliation. The Arthrex Ethics Helpline allows reporting in the reporter’s local language, and is communicated to all employees through internal training and publicly on Arthrex’s website. In 2022, Arthrex implemented a new procedure that sets forth Arthrex’s worldwide process for managing human rights reports that may come through these reporting channels, including guidance for the analysis and review of potential noncompliance. This procedure expands on the Global Policy on Human Rights. Where noncompliance is identified, a corrective action plan, up to and including termination, is put in place.

Training:

Arthrex provides employees with training on its Global Code of Conduct. During this process, employees are required to review and certify their compliance with the Code on an annual basis. In addition, all employees are expected to review and sign the Global Human Rights policy to increase awareness of the risk associated with slavery, human trafficking and human rights. Employees with direct responsibility for supply chain management receive specific training focused on identification and risk mitigation of slavery, human trafficking, and other human rights within the supply chain. The company routinely reviews policies to ensure content is up-to-date and training has been successfully completed.

Effectiveness:

Arthrex periodically evaluates the effectiveness of the actions being taken to address slavery, human trafficking and other human rights risks in our supply chain. In addition, Arthrex continually reviews its risk assessment processes to identify new factors and methods that can be applied. This statement applies to all Arthrex subsidiaries.

 

Signed by:

 

Peter Jensen

VP, Global Risk Management & Compliance

 

Paul Bosworth

General Manager, UK

 

This disclosure is updated annually and was last posted on December 9, 2022.

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