ICU Medical Joint Statement of Compliance with California Transparency in Supply Chains Act (SB 657) and Section 54 of the U.K. Modern Slavery Act

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, 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. ICUMED complies with the Acts’ requirements to disclose the extent to which the company does each of the following - verification, auditing, certification, internal accountability and training.

ICU Medical, Inc. 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 31 December 2017.

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 a Code of Conduct and Business Ethics Policy which 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 Code of Conduct and Business Ethics 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 the Acts. 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.

This Statement is made pursuant to the Acts and constitutes ICUMED’s slavery and human trafficking statement for the previous financial year (FY17).

San Clemente, California, USA

Scott Lamb
Chief Financial Officer
May 3, 2018