Modern Slavery and Human Trafficking Statement

The California Transparency in Supply Chains Act (SB 657) and section 54 of the U.K. Modern Slavery Act 2015 (collectively, “the Acts”) are designed to require manufacturers and retailers, including ICU Medical, to disclose the efforts they take to eradicate slavery and human trafficking from their supply chains. In this joint statement, ICU Medical seeks to demonstrate its compliance with the requirements of the Acts and outlines the steps that have been taken to ensure that slavery and human trafficking is not taking place within any part of its business or its supply chains.

ICU Medical publishes this joint statement on its corporate website in the name and on behalf of itself and its subsidiaries, including ICU UK Medical Limited, for the fiscal year ended FY22.

Organization structure

ICU Medical is one of the world's leading pure-play infusion therapy companies with global operations and a wide-ranging product portfolio that includes IV solutions, IV smart pumps with pain management and safety software technology, dedicated and nondedicated IV sets and needle free connectors designed to help meet clinical, safety and workflow goals. In addition, ICU Medical manufactures automated pharmacy IV compounding systems with workflow technology, closed system transfer devices for preparing and administering hazardous IV drugs and cardiac monitoring systems for critically ill patients.

ICU Medical is headquartered in San Clemente, CA (USA) and is publicly listed.

Supply chains

ICU Medical manufactures and sells innovative medical technologies used in Infusion Therapy and Solutions, vascular therapy, oncology respiratory, general anesthesia and critical care applications. ICU Medical purchases services, raw material, components and finished good to support our global operations from suppliers located in all regions of the world. ICU Medical utilizes multiple modes of transportation to transport the materials to points of use.

Policies in relation to slavery and human trafficking

ICU Medical is committed to conducting its business in a lawful and ethical manner and expects its suppliers to conduct themselves in the same manner. ICU Medical maintains a Code of Conduct and Business Ethics (the “Code”) that applies to all employees and board members of ICU Medical (collectively, "Employees"). The Code requires Employees to comply with all applicable laws and regulations, including laws against human trafficking and slavery.

Additionally, ICU Medical maintains a Reporting and Responding to Compliance Issues Policy. This policy sets out the duty of all Employees to report and raise compliance issues, as well as the procedures ICU Medical will follow when a violation is found to have occurred. It contains the processes ICU Medical will follow with respect to investigations, possible disciplinary actions and remedial actions, as appropriate. ICU Medical also maintains a Discrimination, Harassment and Workplace Bullying Policy to ensure that all Employees are treated with dignity and respect.

In its efforts to confirm compliance with such contractual provisions and to document compliance with the Acts, ICU Medical communicates to its vendors/suppliers its 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. ICU Medical operates a Supplier Code of Conduct (“Supplier Code”) through which it ensures suppliers are held to the highest standards of business conduct. ICU Medical expects its Suppliers to comply with the Supplier Code and reserves the right to discontinue business relationships with suppliers where breaches of the Supplier Code are found to have occurred. Suppliers are therefore expected to regularly take measures to audit and eliminate any form of slavery, forced labor or human trafficking within their business or within the business of counterparties with whom they work.

Due diligence process

Verification
ICU Medical provides a questionnaire to suppliers operating in high risk countries and requires their participation and answers. Upon receipt and review of the questionnaire, if any answers appear to be unacceptable, ICU Medical further investigates the supplier. Additionally, ICU Medical monitors any adverse events relating to its critical suppliers and takes corrective action when required.

Auditing
Suppliers are required to permit ICU Medical to conduct on-site audits for contractual compliance as may be deemed necessary.

Risk assessment and management

ICU Medical requires all Employees and contractors to follow the standards and principles set forth in the company’s Code and Supplier Code. Employees who fail to comply are subject to disciplinary action and contractors who fail to comply may be dropped from ICU Medical’s supply chain.

ICU Medical will hold all employees and contractors accountable to comply with the Acts. ICU Medical 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.

Ongoing monitoring and assessments

Monitoring and addressing modern slavery risks is something that requires on-going attention. It is something that is constantly moving and evolving, and ICU Medical will continue to monitor and improve its modern slavery and human rights programs. ICU Medical maintains a Human Rights Policy which underlines its commitments to human rights and ethical labor practices. ICU Medical will continue to develop a better understanding of country specific and supply chain risks so that its understanding, training, programs, policies and due diligence can be further improved.

Training

In FY23, ICU Medical will incorporate the Human Rights Policy into its internal documentation and training system and will train employees on knowledge and information that will help them understand what slavery and human trafficking are, and how to mitigate the risk of them in ICU Medical’s supply chain. Employees will be required to complete such training on an annual basis.

This Statement is made pursuant to the Acts and constitutes ICU Medical’s slavery and human trafficking statement for the previous financial year (FY22).

San Clemente, California, USA

This statement was approved by the respective Boards of ICU Medical, Inc. and ICU UK Medical Ltd., October 2023.