California Transparency in Supply Chains Act (SB 657)

The California Transparency in Supply Chains Act (SB 657) was enacted into law requiring manufacturers and retailers, including ICU Medical, Inc.(henceforth  ICUMED), to disclose the efforts they take to eradicate slavery and human trafficking from their direct supply chains for tangible goods offered for sale. SB 657 requires the disclosure of the extent, if any, the retail seller or manufacturer does each of the following: verification, auditing, certification, internal accountability and training.

Verification

ICUMED provides each supplier with a questionnaire and requires their participation and answers. Upon receipt and review of the questionnaire, if any answers appear to be unacceptable, ICUMED further investigates the supplier.

Auditing

Each supplier is required to permit ICUMED to conduct on­‐site audits for contractual compliance as may be deemed necessary. ICUMED has not engaged third parties to conduct audits.

Certification

ICUMED is committed to conducting its business in a lawful and ethical manner and expects its suppliers to conduct themselves in the same manner. ICUMED has an Ethical Code of Conduct and Legal Compliance Policywhich applies to all employees and board members of the company (collectively, "Employees"). This policy requires Employees to comply with all applicable laws and regulations, including laws against human trafficking and slavery.

In its efforts to confirm compliance with such contractual provisions and to document compliance with the bill, ICUMED communicates  to our vendors/suppliers  our opposition to any form of slavery and human trafficking and our requirements that they verify and certify their compliance with laws on human trafficking and slavery.  

Internal Accountability

ICUMED requires all team members and contractors to follow the standards and principles set forth in the company's Ethical Code of Conduct and Legal Compliance Policy. Team members who fail to comply are subject to disciplinary action and contractors who fail to comply may be dropped from ICUMED's supply chain.

ICUMED will hold all employees and contractors  accountable  to comply with SB 657. ICUMED takes the issues of slavery  and  human  trafficking  very seriously  and  will  enforce  a  zero  tolerance  policy  and  take  all  necessary measures, within the limits of the law, to appropriately address and eradicate these in instances where we become aware of an employee,  vendor or supplier participating  directly or indirectly in the trafficking  or enslavement  of human beings. 

Training

ICUMED incorporates this policy into its internal documentation system and trains managers and employees who have direct responsibility for supply chain management on knowledge and information that will help them understand what slavery and human trafficking are and how to mitigate the risk of them in their supply chain. These employees will be required to complete such training on an on-­‐going periodic basis.