U.K. Modern Slavery Act Statement
For the Year Ended December 31, 2019
This statement (the “Statement”) of Boston Scientific Corporation for the year ended December 31, 2019 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 2019, 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. In addition, following closing of our acquisition of BTG plc, we added a Specialty Pharmaceuticals business.
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. Following the completion of the acquisition of BTG plc during the third quarter of 2019, we began to integrate BTG’s Interventional Medicine portfolio into the PI division, adding complementary technologies in the areas of venous disease and interventional oncology.
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 to 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.
Specialty Pharmaceuticals. In addition, our Specialty Pharmaceuticals business is an operating segment, presented alongside our three reportable segments. Our Specialty Pharmaceuticals business develops and manufactures acute care antidotes to treat overexposure to certain medications and toxins.
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 and works with teams across the company to monitor our activities and performance. 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. The chief compliance officer reports quarterly to the Audit Committee of our Board of Directors and more frequently as needed.
The Boston Scientific Code of Conduct (the “Code”) is the foundation for our existing policies. All employees, including employees responsible for supply chain management, are required to comply with the Code. All employees participate in annual training on the Code which includes training on ethical decision making and upholding laws and regulations, to ensure understanding and compliance with the requirements of the Code. In 2019, we completed a year-long effort to update the Boston Scientific Code of Conduct. Changes range from additional language about our Corporate Social Responsibility (CSR) commitment to expanded provisions on conflicts of interest and patient and data privacy. The updated Code of Conduct went into effect on January 1, 2020. To promote compliance with the Code, 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 call, 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 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 commitment to human rights, environmentally sustainable practices, as well as 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. 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 agreement to comply with all laws and regulations applicable to the supply of the service or material. Our Supplier Quality team is responsible for ensuring that our vendors understand what is required to meet Boston Scientific’s quality standards. We also monitor our supplier performance through desktop and on-site audits, while continually monitoring incoming material KPIs to confirm compliance with performance and quality standards. Additionally, 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.
As noted above, 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/ Vance R. Brown
Vance R. Brown