ICU Medical Human Rights Policy
1. Purpose
1.1 ICU Medical, Inc. and its subsidiaries ("ICU Medical" or the “Company”) stands against all forms of human rights abuses. In particular, conduct that exploits ICU Medical Personnel of all classifications, whether through intimidation, violence, or denial of rights is inconsistent with ICU Medical values and will not be tolerated. As a global organization, we believe we have a role to play in upholding human rights and defending against adverse human rights impacts.
1.2 ICU Medical is committed to operating at the highest level of ethical standards. We are committed to ensuring our entire supply chain and all actors within it, including recruitment agencies or providers of labor, operate in accordance with our principles and share our commitment to human rights. ICU Medical will work on an ongoing basis to ensure that our supply chain and workforce is free from modern slavery and human rights violations.
1.3 ICU Medical developed this Human Rights Policy (this “Policy”) to set out the details on the standards of labor rights we aim to uphold and commits to promoting human rights in accordance with the United Nations Universal Declaration of Human Rights. At a minimum, we expect our Suppliers, partners and any counterparties with whom we work to uphold the same standards.
2. Definitions
2.1 For purposes of this Policy, the following terms have the following meanings:
2.1.1 “Employment” includes any ICU Medical Employee who is employed at-will or has contracted with ICU Medical.
2.1.2 “ICU Medical Personnel” includes ICU Medical officers, directors and full-time, part-time, and contract employees of ICU Medical.
2.1.3 “ICU Medical Products” refers to products that have been registered, cleared, and/or approved by the appropriate regulatory body and that are manufactured, sold, leased, loaned, rented, or distributed by ICU Medical, and includes services provided by ICU Medical related to such products.
2.1.4 “ICU Medical Service” or “Service” means any service provided by ICU Medical Personnel including clinical, project management, and product implementation (including IT-related implementation and integration with electronic medical record systems, and product-related field services).
2.1.5 “Supplier” or “Suppliers” includes an entity, organization, or individual that supplies goods or services to, or on behalf of, ICU Medical and includes distributors.
3. Scope
3.1 This Policy applies to all ICU Medical Personnel as well as consultants and independent contractors providing services on behalf of ICU Medical. ICU Medical also expects its Suppliers to adhere to this Policy and adopt similar policies within its own businesses.
4. Policies
4.1 ICU Medical against child labor. In accordance with the UN Convention on the Rights of the Child, neither ICU Medical nor its Suppliers will employ or contract anyone who is younger than the legal minimum age or the age established for completing compulsory education in a given country. The Employment of those under the age of fifteen is prohibited. We expect that young people (i.e., those under the age of 18) will not be engaged in work that could be hazardous to their physical, mental or moral wellbeing.
4.2 ICU Medical against forced or involuntary labor. All work conducted for ICU Medical, and its Suppliers, must be conducted on a voluntary basis. ICU Medical will not tolerate any labor enforced by threats of violence or force. ICU Medical will not tolerate any prison labor, indentured or indebted labor, modern forms of slavery, and any form of human trafficking within its workforce or that of its Suppliers.
4.3 Recruitment Fees. Under no circumstances should any ICU Medical Personnel be charged in relation to their recruitment to work at ICU Medical or to any of our Suppliers. All recruitment fees will be borne by ICU Medical or by the relevant Supplier entity.
4.4 Personal Identification Documentation. Confiscation or withholding of personal identification documentation belonging to ICU Medical Personnel is strictly prohibited. Where it is required that copies of personal identification documents are taken for administrative purposes or for safekeeping, they shall always be returned immediately to ICU Medical Personnel.
4.5 Wages, Work Hours and Benefits. ICU Medical also expects that all ICU Medical Personnel be properly remunerated for their service. All Suppliers and third parties with whom ICU Medical works must pay at least the minimum wage guaranteed by local laws. All legally mandated benefits and leaves of absence must also be provided. Under no circumstances should wages be deducted as a disciplinary measure. ICU Medical also expects that all ICU Medical Personnel work in accordance with local laws on maximum working times in any given country.
4.6 Workplace Safety, Security, Treatment; Equality; Movement.
4.6.1 The safety and health of ICU Medical Personnel is of utmost importance to the Company. ICU Medical’s policy is to provide a safe and healthy workplace and comply with applicable safety and health laws and regulations, as well as internal policies. ICU Medical works to provide and maintain a safe, healthy and productive workplace, in consultation with ICU Medical Personnel, by addressing and remediating identified risks of accidents, injury and health impacts.
4.6.2 ICU Medical will not tolerate any harsh or inhumane treatment of ICU Medical Personnel nor the personnel of its Suppliers. This includes, but is not limited to, any physical or mental punishment, verbal abuse, threats or intimidation.
4.6.3 ICU Medical Personnel shall always be treated with dignity and respect. No use or threat of violence, intimidation, retaliation or harassment will be tolerated against ICU Medical Personnel and will be dealt with under appropriate ICU Medical disciplinary procedures. Harassment is not tolerated in the workplace and in any work-related circumstance outside the workplace. ICU Medical also strongly believes in protecting the rights of all ICU Medical Personnel, including women and minority groups. ICU Medical Personnel shall be treated fairly and equally, free from discrimination or bias.
4.6.4 ICU Medical operates a Discrimination, Harassment & Workplace Bullying Policy which underlines ICU Medical's commitment to all people being treated with decency, dignity and respect and its zero-tolerance approach to discrimination, harassment or retaliation against ICU Medical Personnel as well as job applicants, contractors and interns. A copy of ICU Medical's Discrimination, Harassment & Workplace Bullying Policy can be found on ICU Medical’s Human Resources intranet site.
4.6.5 ICU Medical Personnel will not have their movement unreasonably restricted or be physically restricted or confined to their workspace or accommodation.
4.7 Freedom of Association and Collective Bargaining. In accordance with the International Labor Organization (ILO) Core Conventions, ICU Medical supports the freedom of association and the right to bargain collectively.
5. Grievance and whistleblowing mechanisms
5.1 ICU Medical maintains, and expects its Suppliers to maintain, grievance and whistleblowing procedures through which ICU Medical Personnel can raise concerns. Issues should be dealt with promptly by an appropriate level of management. ICU Medical complies with a Reporting and Responding to Compliance Issues Policy, under which, ICU Medical Personnel can report any issues or concerns via an anonymous and confidential hotline, e-mail address or web submission, as further described in Section 7 of this Policy.
6. Ongoing monitoring
6.1 ICU Medical is committed to regularly auditing and monitoring its business to ensure that we are operating free of human rights abuses. Our Board of Directors has adopted this Policy and is responsible for its oversight and for periodically reviewing it to ensure it remains fit for purpose. Implementation of this Policy is the responsibility of all ICU Medical Personnel.
6.2 Further information on ICU Medical's commitment to human rights and the eradication of modern slavery can be found in the following sources:
6.2.1 Modern Slavery Statement
6.2.2 Code of Conduct and Business Ethics
6.2.3 Supplier Code of Conduct
7. Reporting by Employees
7.1 ICU Medical Personnel have a positive duty to report any actual, potential or suspected breach of this Policy or any other action which they have reason to believe would constitute a failing in terms of human rights or modern slavery. ICU Medical believes in an open culture where ICU Medical Personnel are free to speak up on issues that concern them. ICU Medical Personnel may make confidential reports to his/her supervisor, HR, the Compliance Officer, or the General Counsel. ICU Medical Personnel may also report any concerns through an anonymous and confidential hotline at 1-844-330-0007. Anonymous and confidential reports can also be made by email to reports@lighthouse-services.com (must include Company name in the report), through confidential web submission at www.lighthouse-services.com/icumed,or via the Governance Reporting section in our corporate governance website at https://ir.icumed.com/corporate-governance.
8. Auditing and Monitoring
8.1 This Policy, together with supporting documentation and records required by it, is subject to periodic auditing and monitoring.
9. Exceptions
9.1 Any exceptions to the requirements of this Policy must be approved by ICU Medical’s General Counsel.