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California Transparency in
Supply Chain Act of 2010

The California Transparency in Supply Chains Act of 2010 is intended to provide public information from manufacturers and retailers regarding their efforts to prevent human trafficking and slavery, which will allow businesses and consumers to make more informed decisions regarding the products they choose to purchase and the companies with whom they choose to conduct business.

Boston Scientific is 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 relating to human trafficking and slavery. Boston Scientific has undertaken many actions to ensure that the services and materials provided to Boston Scientific meet this commitment.

Boston Scientific Code of Conduct

Boston Scientific's Code of Conduct outlines the company's expectations for business conduct and practices and includes provisions on conducting business with high ethical and legal standards. All suppliers are expected to comply with the Code of Conduct.

Supplier Assessments and Qualification

Prior to engagement of a supplier, Boston Scientific evaluates the supplier through a risk-based assessment, which may include supplier questionnaires and audits of supplier facilities. Boston Scientific's expectation for compliance with ethical and quality standards are communicated to all potential suppliers.

Supplier Performance Reviews

Boston Scientific is committed to continuous improvement in its supply chain. Once a material supplier is engaged, Boston Scientific and the supplier develop performance targets and objectives and Boston Scientific monitors business performance through periodic evaluation and review of these performance targets and objectives.

Supplier Audits

Boston Scientific also regularly audits suppliers who impact our quality system to confirm compliance with supplier performance and quality standards. Audits are performed by Boston Scientific or third parties contracted by Boston Scientific.

Supplier Agreements

Boston Scientific has supply agreements, quality agreements and/or purchase order terms and conditions with all of its suppliers. These contracts include certification and agreement to comply with all laws and regulations applicable to the supply of the service or material.

Employee Training and Compliance

All Boston Scientific employees, including employees responsible for supply chain management, are required to comply with Boston Scientific's Code of Conduct. All Boston Scientific 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, Boston Scientific maintains a compliance program that conducts regular audits of the requirements under the Code, investigates potential violations of the Code and takes disciplinary action when necessary.