Inclusivity and workforce safety help us stay strong in a competitive marketplace. We act with transparency and develop our employees to create a workplace where everyone can thrive.
Boston Scientific strictly adheres to all labor and human rights laws, including those related to slavery, child labor, human trafficking, bribery, discrimination, harassment and pay equity, and requires that our third party partners do as well.
Boston Scientific’s commitment to embracing and exemplifying inclusiveness extends throughout our business. We believe in maximizing the individual contributions of our employees, and encouraging the teamwork that makes us a stronger company. We believe that the similarities, the differences and the power of our people allow us to sustain competitive advantages that lead to extraordinary business results. And we are committed to those beliefs because a truly inclusive work environment - one with a richness of backgrounds and perspectives - is a better, more rewarding place to work.
Support of United Nations International Bill of Rights
The International Bill of Human Rights consists of the Universal Declaration of Human Rights, the International Covenant on Economic, Social and Cultural Rights, and the International Covenant on Civil and Political Rights and its two Optional Protocols. Its basic tenet is as follows: “All human beings are born free and equal in dignity and rights. They are endowed with reason and conscience and should act towards one another in a spirit of brotherhood.” Boston Scientific supports the UN International Bill of Human Rights.
Commitment on United Nations Guiding Principles on Business and Human Rights
Boston Scientific believes that corporations have a responsibility to respect and protect human rights. Boston Scientific supports the UN’s foundational principles of human rights, including the following:
Boston Scientific supports the rights of children to have access to education, healthcare, and protection from criminal behavior.
- Boston Scientific respects human rights, seeks to avoid infringing on the human rights of others, and seeks to address adverse human rights impacts with which they are directly involved.
- In order to meet this responsibility, Boston Scientific has policies, procedures and processes appropriate to its size and circumstances that help it fulfill its responsibility to respect human rights and enable the remediation of any adverse human rights impacts caused by Boston Scientific.
Commitment to Local Labor and Sourcing
Boston Scientific seeks to recruit and employ local labor when it is compatible with company strategy and hiring needs, as well as product quality and regulatory requirements.
Human Rights Risk Assessment
Boston Scientific complies with US and international human rights principles and conventions as explained in the Compliance and Ethics section of the Boston Scientific internet site. When reviewing existing or planned operations, human rights aspects are assessed under these criteria.
Stakeholder Engagement to Verify Human Rights
Boston Scientific is committed to acting ethically in dealing with customers, employees, shareholders, partners, suppliers, competitors and the community, and with respect for applicable laws. One way we make this happen is through the implementation of our Global Compliance Program. The primary purpose of this program is to detect and prevent violations of laws, regulations, and company policies, taking into account and tailoring the program to our unique environment. Our Code of Conduct is a cornerstone of our compliance program and provides guidance regarding business conduct and practices to all Boston Scientific team members.
Grievance Mechanism for Individuals Impacted by Business
Our Global Compliance Program is designed to meet each of the elements of an effective compliance program and Boston Scientific is committed to acting ethically in dealing with customers, employees, shareholders, partners, suppliers, competitors and the community and with respect to applicable laws. Individuals can contact the Advice Line to ask a question, raise a concern or file a report relating to integrity in the workplace; this process allows questions or concerns to be raised anonymously if the individual so desires. The Advice Line is managed by an independent third-party vendor, and each issue raised within this process is tracked and investigated.
Actions Taken on Human Rights Violation
Boston Scientific is unaware of any human rights violations perpetrated by the company, its employees and its affiliates in the past 5 years. In the event that Boston Scientific determined such a violation occurred, Boston Scientific would take swift and appropriate action to address the issue, as previously discussed.
Participation in Human Rights Initiatives
Boston Scientific encourages employees to participate in human rights initiatives. Reflecting this commitment to human rights, Boston Scientific received a perfect score of 100 percent on the 2015 Corporate Equality Index (CEI), a national benchmarking survey and report on corporate policies and practices related to lesbian, gay, bisexual and transgender (LGBT) workplace equality, administered by the Human Rights Campaign (HRC) Foundation.
Output of Community Investments
Boston Scientific supports our communities through a combination of charitable giving and volunteerism. As discussed in the Corporate Citizenship, Giving section of the company’s web site, donations and grants are provided to multiple local organizations, with additional detail provided in the Boston Scientific Foundation annual report.
Boston Scientific supports extensive community volunteer activity. As a whole, the company advances major health initiatives through its involvement with the American Heart Association, World Stroke Day, and Pancreatic Cancer Research. At a local level, BSC employees are provided time to participate in volunteer activities to benefit their local communities, ranging from providing specialized housing for those in need, assisting children with special needs, conducting clean-up work in conservation areas, and planting trees in deforested areas. Further discussion of these types of community investments can be found on the Company internet site in the Corporate Citizenship, Community Involvement section and Sustainability section, as well as the 2014 Boston Scientific Global Sustainability Report.
Employee Engagement with Charitable Partners
Boston Scientific provides dedicated time for employees to volunteer in the communities where they live and work. Partnering organizations include local and national non-profit organizations, local schools, environmental non-governmental organizations, and local health care organizations.
Amount of Donations/Community Investments
In 2013, Boston Scientific provided approximately $1 million in grants and donations to community partners.
Boston Scientific has significant headcount and operations in the United States, Ireland, the Netherlands, Costa Rica and Japan. Boston Scientific operates in a limited number of countries of concern (e.g., China, India and South Africa) with regional headquarters, training centers or sales offices, employing professional employees at these locations. Boston Scientific's goal is to operate in accordance with the United States Department of Labor and International Labour Organisation's Core Conventions.
Boston Scientific prohibits all forms of child labor as prohibited by the Unites States Department of Labor, Fair Labor Standards Act (FLSA) and International Labour Organisation (ILO), conventions C138 and C182.
Boston Scientific prohibits all forms of forced labor or exploitative working conditions as prohibited by the United States Department of Labor, Fair Labor Standards Act (FLSA) and International Labour Organisation (ILO), conventions 29 and 105.
Boston Scientific is committed to following fair employment practices that provide equal opportunities to all employees. We do not discriminate or allow harassment on the basis of race, color, religion, disability, gender, national origin, sexual orientation, gender identity, gender expression, age, genetic information, military status, or any other legally protected status. This is further described on Boston Scientific’s company internet page under Compliance and Ethics and the Code of Conduct Policy.
Boston Scientific supports the right of individuals to join or leave groups of their choosing in accordance with their personal and social interests.
Boston Scientific adheres to the United States Department of Labor and International Labour Standards conditions and regulations on Collective Bargaining.
Boston Scientific provides employees with regulated hours of work, rest periods and time off consistent with ILO Standards, Working Time and the United States Department of Labor, Work Hours.
Boston Scientific supports the right of individuals to earn such a wage as to be able to afford goods or services for quality of life, food, utilities, transport, healthcare, education, childcare, and personal recreation. This living wage may be in excess of the minimum wage rates and requirements by country. Boston Scientific strives to compensate all employees fairly for the skills and activities performed.
Commitment to Labor Initiatives or Standards
Boston Scientific has limited presence in countries of concern. Those locations consist of sales offices, training centers or regional headquarters staffed by professional employees compensated above minimum or legally required standards.
Employment of Under-Privileged and Youth, and Apprenticeships
Boston Scientific actively works with local schools and organizations to provide summer and internship opportunities for under-privileged youths. In addition, mentoring events related to Science, Technology, Engineering and Mathematics (STEM) are held with local schools, to encourage youth to pursue careers in these areas.
Boston Scientific provides employees access to policies and information related to policies on the Company intranet site. There is also regular communication and training on the policies and associated relevant changes. Related policies are also discussed on the company’s internet site under Compliance and Ethics and the Code of Conduct Policy. The Code of Conduct is available in multiple languages to assure global employee access to this information.
Risk Assessment Related to Labor Issues
This aspect is addressed within Boston Scientific’s Global Compliance Program, discussed on the company’s internet site under Compliance and Ethics.
Actions Taken on Issues Related to Child Labor, Forced Labor, Excessive Hours, etc.
Boston Scientific, in accordance with local labor laws, does not tolerate managers, contractors, or outside consultants who are found to be in violation of multiple labor issues and such relationships may be terminated.
Actions Taken on Issues Related to Diversity, Equal Opportunity and Discrimination
Boston Scientific is committed to following fair employment practices that provide equal opportunities to all employees. We do not discriminate or allow harassment on the basis of race, color, religion, disability, gender, national origin, sexual orientation, gender identity, gender expression, age, genetic information, military status, or any other legally protected status. Boston Scientific also values diversity and believes that a diverse workplace builds a true competitive advantage.
Actions Taken Related to Labor Non-Compliance
Boston Scientific’s Global Compliance Program is designed to meet each of the elements of an effective compliance program and Boston Scientific is committed to acting ethically in dealing with customers, employees, shareholders, partners, suppliers, competitors and the community and with respect to applicable laws. In the event of a non-compliance event, our Global Compliance Program describes associated response actions, and if warranted, consequences.
Boston Scientific’s annual 2017 turnover rate for full-time employees was 11.1%.
Percentage of Contractor and Temporary Staff
During 2017, 14.3% of Boston Scientific’s labor force was constituted by contract workers.
Employee Development Training
Boston Scientific strongly believes in investing in the personal and professional development of our employees, so they can aspire to higher goals and achieve more in their career. Programs are offered to employees, such as a young professionals’ development program, to assist employees in their personal growth, based upon their skill sets, goals and professional maturity. In addition, employees are asked to complete an Individual Development Plan (IDP) at the beginning of the year, to help them set goals aligned with their development and assure that the supporting resources are available for them to be successful in these areas.
Boston Scientific operates a sales office, with a limited number of professional employees, in Bryanston, South Africa. These employees participate in the training and development activities described above. Based upon the nature of the activity in South Africa, and the absence of a manufacturing presence, participation in other programs such as Broad Based Black Economic Empowerment would not be applicable.
U.K. Modern Slavery Act Statement
For the Year Ended December 31, 2017
This statement (this “Statement”) of Boston Scientific Corporation for the year ended December 31, 2017 is prepared in accordance with the United Kingdom Modern Slavery Act 2015 (the “Act”). The Act requires us to set forth the steps taken to ensure modern slavery, as such term is defined in the Act, is not taking place in our business or supply chains. Generally, modern slavery is defined as offenses of slavery, servitude and forced or compulsory labor and human trafficking. When used in this Statement, the terms “we,” “us,” “our,” “Boston Scientific,” “BSC” and “the Company” mean Boston Scientific Corporation and its divisions and subsidiaries.
Information on or connected to our website (or the website of any third party) referenced in this Report is in addition to and not a part of or incorporated by reference into this Report. Such additional information speaks as of the date thereof and is not intended to be confirmed or updated by reference herein. Boston Scientific disclaims any liability or responsibility for or endorsement of the information on or connected to the website of a third party.
Boston Scientific is dedicated to transforming lives through innovative medical solutions that improve the health of patients around the world. We are a worldwide developer, manufacturer and marketer of medical devices that are used in a broad range of medical specialties. These products are generally sold directly or through distributors and agents to hospitals or physicians, making Boston Scientific the final step in the supply chain prior to these products reaching the end customer.
During 2017, our products were offered for sale by seven core businesses: Interventional Cardiology (“IC”), Peripheral Interventions (“PI”), Cardiac Rhythm Management (“CRM”), Electrophysiology, Endoscopy, Urology and Pelvic Health, and Neuromodulation.
Our seven businesses are organized in three segments:
Cardiovascular segment. In IC, we focus on technologies for diagnosing and treating coronary artery disease and other cardiovascular disorders that affect large patient populations. We also offer structural heart products, which include devices for transcatheter aortic valve replacement and an alternative to blood thinners for reducing atrial fibrillation stroke risk. Our PI business develops solutions designed to treat peripheral artery disease, deep vein thrombosis and cancer.
Rhythm and Neuro segment. In CRM, we provide innovative technologies for the treatment of cardiac arrhythmias, heart failure and sudden cardiac arrest, for example, implantable cardioverter defibrillator systems and pacemaker systems. Our Electrophysiology business develops less-invasive medical technologies used for diagnosing and treating complex arrhythmias. Our Neuromodulation business offers microelectronic implantable technologies help manage chronic pain and neurological conditions.
MedSurg segment. In Endoscopy, we offer devices to diagnose and treat a variety of gastrointestinal and pulmonary conditions. Our Urology and Pelvic Health business focuses on solutions for urological, urogynecological and gynecological diseases.
Boston Scientific Employee Compliance and Ethics
We are committed to acting ethically and in compliance with all applicable laws. We support this commitment through our robust global compliance program. Our Global Compliance team, led by our chief compliance officer, supports the company’s worldwide culture of compliance and ethics through partnerships and collaboration with commercial team members and other key stakeholders. The primary purpose of our compliance program is to support our culture of integrity and to detect and prevent violations of laws, regulations and company policies, taking into account and tailoring the program to our unique environment.
Our Code of Conduct is the foundation for our existing policies. All of our employees, including employees responsible for supply chain management, are required to comply with the Boston Scientific Code of Conduct. All of our employees participate in annual training on the Company's Code of Conduct, which includes training on ethical decision making and upholding laws and regulations, to ensure understanding and compliance with the requirements of the Code. To promote compliance with the Company's Code of Conduct, we maintain a compliance program that conducts regular audits of the requirements under various compliance policies, investigates potential violations of the Code and takes disciplinary action when necessary. We also maintain an Advice Line, a toll-free number that anyone can all, 24 hours a day, seven days a week, to obtain guidance, report an integrity concern, or suspected violation of the Code of Conduct or other policy.
Boston Scientific Supply Chain
We are committed to conducting business only with suppliers who adhere to the highest ethical standards and comply with laws and regulations applicable to their business, including laws related to human trafficking and slavery. We are further committed to promoting principles of human rights as recognized and understood by the international community, which includes freely chosen employment, avoidance of child labor, reasonable working hours, fair wages and benefits, and humane treatment. Evaluating potential partnerships against our strict criteria takes time, but partnerships with responsible suppliers are a fundamental component of our business continuity and risk mitigation strategy. Among other areas, a potential new supplier is evaluated based on its commitment to responsible business practices, sustainability, and social responsibility. This includes a review of the supplier’s corporate principles, core values, and code of conduct policies to assess commitment and adherence to responsible business practices, including upholding human rights and vigilance against human trafficking and slavery. All suppliers are also expected to comply with the Boston Scientific Code of Conduct. Prior to engagement of a supplier, we evaluate the supplier through a risk-based assessment, which may include supplier questionnaires and audits of supplier facilities. Our expectations for compliance with ethical and quality standards are communicated to all potential suppliers. These principles and expectations are articulated in our Supplier Guidebook. The Supplier Guidebook is available for viewing here.
We have strong engagement with our suppliers, through supply agreements, quality agreements and/or purchase order terms and conditions. These contracts include certification and agreement to comply with all laws and regulations applicable to the supply of the service or material. We also conduct audits to confirm compliance with performance and quality standards, and we have in place a Supplier Resiliency and Risk program which uses internal systems as well as a third-party platform to monitor risk. This system alerts us to supply issues throughout our supply chain based on publicly available information, including those presenting risks in the corporate social responsibility area.
Additionally, we maintain an advice line, accessible here, whereby employees and third parties, including suppliers, may ask questions, obtain guidance or report concerns. Employees and business partners are encouraged to raise questions when they need guidance or clarification and to report any concerns or suspected violations of the Code of Conduct, other Company policies, procedures and/or applicable laws.
Boston Scientific Corporation
/s/ Michael F. Mahoney
Michael F. Mahoney
Chairman, President and Chief Executive Officer
Boston Scientific Limited
/s/ Mark R. Slicer
Mark R. Slicer