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