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Responsibility Standards for Lifescan Suppliers

LifeScan’s Supplier Message

LifeScan is committed to conducting business in accordance with all applicable laws, rules and regulations and in line with the LifeScan Code of Conduct, which can be found at LifeScan.com. We are dedicated to doing the right thing and seek only to work with suppliers whose standards are consistent with our own.

Commitment to this Code

On this basis, our suppliers are required to carry out their business in accordance with all applicable laws, rules and regulations and to comply with this (“Code”) when working for LifeScan. The Code reflects the principles and behaviours contained within the LifeScan Code of Conduct. Our suppliers are also expected to ensure that their own suppliers operate in line with the standards within this Code, where involved in activities on behalf of LifeScan.

Guiding Principles

LifeScan Global Corporation and its affiliates (Lifescan) hold themselves to high standards that, along with our management philosophy, are embodied in our values. These Standards reflect our internal values and the expectations of external stakeholders, such as customers, regulators, investors and the public. We find business relationships are more productive and effective when they are built on trust, mutual respect and common values, and seek relationships with suppliers who share a common commitment to:

  • Comply with applicable laws and regulations;
  • Behave ethically and with integrity;
  • Integrate quality into business processes;
  • Respect human and employment rights;
  • Promote the safety, health and well-being of employees;
  • Embrace sustainability and operate in an environmentally responsible manner;
  • Implement management systems to maintain business continuity, performance governance and continuous improvement; and
  • Disclose information associated with the supplier’s impact on the environment and social issues.

RESPONSIBILITY STANDARDS FOR SUPPLIERS

We believe that when these guiding principles are followed, both businesses and communities realize economic, social and environmental benefits. We developed the following set of Standards to assist us with selecting suppliers that operate in a manner consistent with these guiding principles and to support our suppliers in understanding and upholding our expectations. We strive to include elements of these standards in supplier selection, purchasing contracts and engaging in business. Lifescan may take steps to assess a supplier’s conformance to them and may work with suppliers to identify agreed upon actions and timelines to achieve improvement. LifeScan consider progress in meeting these expectations and ongoing performance in their sourcing decisions.

Legal Compliance

Suppliers to LifeScan are expected to operate in compliance with all applicable laws, and regulations of the countries, states and localities in which they operate. This includes, but is not limited to, laws and regulations related to ethical business practices, quality, labor and employment practices, as well as health, safety and environmental protection. Suppliers are also expected to conform their practices to generally accepted industry standards, obtain and maintain all applicable permits, licenses and registrations, and operate in accordance with permit limitations and requirements at all times.

Ethics and Business Conduct

Suppliers to LifeScan are expected to behave ethically and with integrity in all business transactions. As such, they shall:

  • Uphold standards for fair business practices including accurate and truthful advertising, and fair competition;
  • Prohibit the payment of bribes, illegal political contributions, or other illicit payments or consideration for any reason, including the waiver of penalties or fines or the receipt of any other special benefits or gifts;
  • Prohibit financial or professional conflicts of interest;
  • Ensure that workers report concerns or illegal activities in the workplace without threat of reprisal, intimidation or harassment;
  • Safeguard against improper use of intellectual property, including disclosure of confidential or sensitive information, including pricing, employee and patient information;
  • Maintain an environment of transparency, collaboration and innovation; and
  • Treat any animals used in its activities in an ethical and humane manner and follow the principles of replacement, refinement and reduction of laboratory research animal testing.

If such conflicts arise or appear to arise, suppliers must, where possible, mitigate them and promptly report all incidents to LifeScan.

Quality

Suppliers to LifeScan are expected to provide goods and services that consistently meet customers’ needs, are safe for their intended use and perform as intended. While suppliers must meet the specifications agreed upon in the applicable agreement, purchase order or other contractual relationship, suppliers must also meet certain minimum quality requirements including compliance with regulations where their products may be sold. As such, they shall:

  • Establish and maintain a Quality System and Quality controls to protect the integrity of the goods and services provided;
  • Provide written notification to LifeScan of proposed changes to specifications, methods, suppliers, materials/components, manufacturing/supply process, manufacturing location or equipment in order to determine impact on LifeScan’s products;
  • Ensure good documentation practices are established and maintained;
  • Permit LifeScan or an authorized delegate to conduct Quality audits of the facilities, systems and/or documents related to the goods and services provided, and promptly provide responses and take corrective actions to remedy any observations cited;
  • Notify LifeScan of significant Health Authority inspections and regulatory issues, such as: warning letters, FDA form 483 observations, letters of non-compliance, seizures and injunctions, including any observations related to the products of LifeScan;
  • Ensure that all pallets used to supply goods to LifeScan comply with ISPM 15;
  • Provide written notification to LifeScan of any Quality issues which could impact the form, fit or function of the product or services provided to LifeScan.

Health, Safety and Well-being of Employees

Suppliers to LifeScan shall comply with all applicable laws and regulations and provide and maintain a safe and healthy working environment for their employees. As such they are expected to:

  • Provide facilities to assure the health, safety and wellbeing of employees and visitors;
  • Provide employees with appropriate occupational health and safety training;
  • Implement programs to manage health and safety and prevent or control employee exposures to workplace hazards including chemical, biological and physical hazards;
  • Implement programs that promote access to health programs that positively impact the health of employees;

Sustainability and Environmental Responsibility

Suppliers to LifeScan are expected to operate in a sustainable and environmentally responsible manner complying with all applicable laws, regulations and permits. As such, they shall:

  • Implement programs to reduce the environmental impacts of their operations including natural resource consumption, materials sourcing, waste generation, wastewater discharges and air emissions.
  • Implement programs to reduce their impact to climate change and greenhouse gas emissions.
  • Implement programs which promote sustainable business practices.
  • Implement programs to ensure products and packaging do not contain restricted or banned materials.
  • Implement programs to verify that plant/forest materials and derivatives purchased are legally harvested and exported/imported
  • Notify LifeScan if they supply conflict minerals (tin, tantalum, tungsten or gold) to determine if due diligence information or other data is required.

Human Rights, Labor and Employment

Suppliers to LifeScan are expected to treat people with dignity and respect and respect the rights, interests. As such, they shall:

  • Not engage in any form of human trafficking (for example, by using force, fraud or coercion to subject a person to involuntary servitude, peonage, debt bondage or slavery), procure commercial sex acts or use forced labor (for example, by knowingly providing labor from a person by threats of serious harm to that person or another person);
  • Not destroy, conceal, confiscate, or otherwise deny employees, contractors or subcontractors access to such person’s identity or immigration documents, use misleading or fraudulent recruiting practices, use recruiters that do not comply with local labor laws in the country where the recruiting takes place, charge recruiting fees, expect workers to pay for a job, provide housing that does not meet the standards of the country where work is performed, or fail to provide an employment contract or recruitment agreement if required by law;
  • Provide return transport for the person if supplier has transported or paid (directly or indirectly) to transport an employee, contractor or subcontractor from another country to the country where such employee will perform work;
  • Ensure that employees have freedom of movement and are free to leave their employment after reasonable notice;
  • Not discriminate against or harass an individual on the basis of race, color, religion, gender, pregnancy, HIV status, health status, sexual orientation, national origin, age, disability, veteran’s status, marital status, trade union membership or political affiliation;
  • Not treat or threaten to treat an individual harshly or inhumanely. Harsh or inhumane treatment includes sexual harassment or abuse, corporal punishment and/or coercion;
  • Respect workers’ rights to rest and leisure and avoid unsafe working conditions by providing sufficient rest periods during the workday, honor agreed upon days off from work and maximum working hours;
  • Pay fair wages that meet or exceed legal minimum for all hours worked and clearly communicate the wages that employees are to be paid in advance of commencing work. Communicate to all employees if overtime is required and the wages to be paid for such overtime;
  • Comply with laws regarding the age eligibility of workers;
  • Respect workers’ rights to make informed decisions free of coercion, threat of reprisal or unlawful interference regarding their desire to associate freely, join or not join organizations or to peaceful assembly;
  • Respect workers’ rights to bargain collectively without unlawful interference; and
  • Respect workers’ rights to raise concerns in the workplace through a grievance mechanism.

Health Care Compliance

Suppliers to LifeScan and any third-party conducting business on our behalf are expected to uphold our strong stance against bribery and corruption, consistent with the anti-corruption laws that exist in many countries around the world. As such, in connection with any LifeScan relationship, they shall:

  • Follow local and internationally applicable laws and ethical standards and strictly prohibit bribes, kickbacks, illegal payments and any other offer of items of value that may inappropriately influence or reward a customer to order, purchase or use our products and services, whether provided directly or through a third party, such as a distributor, customs broker or other agent;
  • Avoid any other action that could inappropriately influence the medical decisions of health care professionals and the purchasing decisions of entities that buy our products and services, including health care professionals, government regulators and inspection authorities;
  • Respect the privacy of employees and others whose personal information they have access to, by complying with local and applicable international laws when collecting and storing personal information about employees, business partners, patients, health care professionals, consumers and others, such as birth dates, addresses and financial, medical and other information; and
  • Collect personal information only for legitimate business purposes, share only with those who are allowed access, protect in accordance with security policies, retain only for as long as necessary, and contractually obligate third parties with access to personal information to protect it.

Transparency and Disclosure

Suppliers to LifeScan are expected to make reasonable efforts to publicly disclose topics and goals that are important to the organization’s impact on the environment and social issues (e.g., on a website or publicly available report).

Monitoring and Compliance

LifeScan may engage in monitoring activities to confirm a supplier’s compliance to these Standards, including on-site assessments of facilities, use of questionnaires, review of available information or other measures necessary to review supplier’s performance. LifeScan may disqualify any potential supplier that has failed to conform to these Standards.