U.K. Modern Slavery Act Statement
For the Year Ended December 31, 2022
This statement (the “Statement”) of Boston Scientific Corporation for the year ended December 31, 2022 is prepared in accordance with the United Kingdom Modern Slavery Act 2015 (the “Act”) and is made on behalf of the group companies listed below*. 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 labour 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 in the UK.
Information on or connected to our website (or the website of any third party) referenced in this Statement is in addition to and not a part of or incorporated by reference into this Statement. 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 and associated consumables 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 2022, our products were offered for sale by five core businesses:
Endoscopy: Our Endoscopy business develops and manufactures devices to treat a broad range of gastrointestinal and pulmonary conditions with innovative, less invasive therapies.
Urology: Our Urology business develops and manufactures devices to treat various urological and pelvic conditions for both male and female anatomies, including kidney stones, benign prostatic hyperplasia, prostate cancer, erectile dysfunction and incontinence.
Neuromodulation: Our neuromodulation business develops and manufactures devices to treat various neurological movement disorders and manage chronic pain.
Peripheral Interventions (PI): Our PI business develops and manufactures products to diagnose and treat peripheral arterial and venous diseases, as well as products to diagnose treat and ease various forms of cancer.
- Interventional Cardiology (IC): Our IC business develops and manufactures technologies for diagnosing and treating coronary artery disease and aortic valve conditions.
- Watchman: Our WATCHMAN FLX™ Left Atrial Appendage Closure (LAAC) Devices are designed to close the left atrial appendage in patients with non-valvular atrial fibrillation who are at risk for ischemic stroke.
- Cardiac Rhythm Management (CRM): Our CRM business develops and manufactures a variety of implantable devices that monitor the heart and deliver electricity to treat cardiac abnormalities.
- Electrophysiology (EP): Our EP business develops and manufactures less-invasive medical technologies used in the diagnosis and treatment of rate and rhythm disorders of the heart, including a broad portfolio of therapeutic and diagnostic catheters and a variety of equipment used in the Electrophysiology lab.
Boston Scientific Employee Compliance and Ethics
We are committed to act ethically and with integrity in all our working relationships, inside and outside the company and in compliance with all applicable laws. We support this commitment through our robust global compliance program. People and partners across our brands and supply chain trust our ethics and our track record of responsibility.
The Boston Scientific Global Compliance team provides the training and resources our employees need to help ensure they are conducting business responsibly, treating customers and suppliers fairly and reporting any ethics concerns. The team is led by our chief compliance officer, who reports to the full Board of Directors annually, the Risk Committee of the board quarterly and to the Audit Committee as warranted. Our compliance experts collaborate with teams across the business to monitor the company's compliance with Boston Scientific policies and applicable laws.
Every Boston Scientific employee is required to read, understand and follow the Boston Scientific Code of Conduct. The Code is the foundation for all of our business practices and relationships, and is promoted through many channels, including our annual Integrity Week initiatives. In 2022, we also launched a new advice line website to make it easier for employees to report ethics and integrity concerns, 24 hours a day, 7 days a week.
Further, Boston Scientific prohibits any form of retaliation, direct or indirect, against an individual who raises a concern in good faith. This protection extends to anyone who assists with, or cooperates in, an investigation of such a report.
Boston Scientific Supply Chain
We are committed to conducting business 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 work to advance principles of human rights as recognized and understood by the international community, which include freely chosen employment, avoidance of child labour, reasonable working hours, fair wages and benefits, and humane treatment.
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 each potential supplier ahead of any engagement. In 2022, we launched our Supplier Code of Conduct for our preferred and strategic suppliers. This Supplier Code of Conduct sets forth Boston Scientific’s expectations for its suppliers regarding corporate responsibility in the supply chain and provides information and guidance on how to conduct business with ethics and integrity.
Evaluating potential partnerships against our strict criteria takes time, but partnerships with responsible suppliers are a fundamental component of our commitment to human rights and environmentally sustainable practices, as well as to our business continuity and risk mitigation strategies. Potential suppliers are evaluated based on their commitment to responsible business practices, sustainability, and social responsibility, among other areas. 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.
We have strong engagement with our suppliers through supply agreements, quality agreements and/or purchase order terms and conditions. These contracts include agreement to comply with all laws and regulations applicable to the supply of the service or material in all relevant jurisdictions. Our Supplier Quality team is responsible for ensuring that our vendors understand what is required to meet Boston Scientific’s quality standards.
We monitor our supplier performance through desktop and on-site audits, while continually monitoring incoming material key performance indicators to confirm compliance with performance and quality standards. Additionally, 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.
As noted above, we maintain an Advice Line 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.
This Statement has been approved by the Board of Directors of Boston Scientific Corporation.
Chairman and CEO
Boston Scientific Corporation
*This statement is made on behalf of the following group entities in the UK: Boston Scientific Limited, Biocompatibles UK Limited, BTG Limited, BTG Management Services Limited, Provensis Limited and BTG International Limited.
Director of Provensis Limited
Vance R. Brown
Director of all the other above-listed UK entities