Respecting Human Rights
While it is the duty of governments to protect the rights of their citizens, Boston Scientific recognizes that businesses also have a critical role to play. As a global medical device company, Boston Scientific respects and strictly adheres to all labor and human rights laws--including, among others, those related to modern slavery, child labor, human trafficking, bribery, discrimination, harassment and pay equity. We strive to conduct our business ethically and in a way that demonstrates respect for globally recognized human rights and the dignity of all people, and we require the same of our contractors, suppliers and business partners across the globe.
We require the same standards of our contractors, suppliers and business partners across the globe. By way of example, our Supplier Guidebook mandates adherence to all human rights laws and labor standards, and requires that safe and healthy working conditions be maintained at all times.
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 respects human rights, seeks to avoid the infringement upon the human rights of all people, and seeks to address adverse human rights impacts on all people.
- In order to meet this responsibility, Boston Scientific has established appropriate policies and procedures that help it in fulfilling its responsibility to respect and advance human rights while enabling remediation whenever necessary. We expect the same of our contractors, suppliers and business partners across the globe.
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. Some basic tenets are 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 …”
- “No one shall be held in slavery or servitude; slavery and the slave trade shall be prohibited in all their forms …”
- “Everyone has the right to work, to free choice of employment, to just and favourable conditions of work and to protection against unemployment …”
- “Everyone, without any discrimination, has the right to equal pay for equal work …”
- “Everyone who works has the right to just and favourable remuneration ensuring for himself and his family an existence worthy of human dignity … ”
Boston Scientific fully supports the UN International Bill of Human Rights.
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, explained further here. 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.
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.
Grievance Mechanism for Individuals Impacted by Business
Boston Scientific provides a number of resources that employees and others can use to ask a question, obtain guidance, or report a Code of Conduct concern. Read more about the Advice Line here.
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. Our collaboration with partners including historically Black colleges and universities, the Human Rights Campaign, Disability:IN, the Hispanic Association on Corporate Responsibility and the Society of Women Engineers helps support hiring and development of talent from underrepresented groups. All employees participate in unconscious bias training and Boston Scientific has increased training for leaders to foster an understanding of micro-aggressions, the history of racism and how to champion diversity, equity and inclusion.
Our leadership in these areas has been widely recognized, including:
- For the seventh consecutive year, Boston Scientific earned the designation as one of the Best Places to Work for LGBTQ Equality by the Human Rights Campaign Foundation’s Corporate Equality Index (CEI), the foremost benchmarking survey and report in the U.S., measuring corporate policies and practices related to LGTBQ workplace equality. Boston Scientific received a 100% rating, which reflects efforts to foster an equitable, inclusive culture for all employees through our policies, benefits, partnerships and programs.
- For the fifth consecutive year, Boston Scientific was recognized as a Best Place to Work for Disability Inclusion, receiving a 100% score on the 2020 Disability Equality Index (DEI). Developed by two national leaders, American Association of People with Disabilities (AAPD) and Disability:IN, DEI is a national, transparent benchmarking tool that offers businesses an opportunity to self-report their disability inclusion policies and practices.
- For the third consecutive year, Boston Scientific was included in Bloomberg’s Gender-Equality Index. Joining 379 other companies recognized globally this year, the index provides a comprehensive look at how organizations are investing in and advancing gender equality through policy and program development, representation and transparency. This recognition speaks to our continued progress and focus on pay equity, inclusive benefits and recruitment practices, increasing representation of female employees and leaders, and more.
- Boston Scientific was also named to the 2020 Dow Jones Sustainability Index North America, one of the most prestigious benchmarks for corporate responsibility.
Learn more about how Boston Scientific fosters an environment of inclusion, equity and opportunity for all here.
Output of Community Investments
We are united by a goal to make a difference in the lives of the approximately 30 million patients we serve annually. We seek to give our time and resources to make positive impacts upon those communities where we live, work and serve. Guided by our core values, we seek to improve access to healthcare, to invest in educational programming for students with limited means and access to opportunities, and to support and embrace the spirit of volunteerism within our global workforce, while adhering to strong ethical standards. Further discussion of these types of community investments can be found on the company website under the Community Engagement section as well as the 2020 Boston Scientific Global Performance 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 2020, Boston Scientific contributed more than $70 million to support medical research, education and charitable organizations. We also found new and creative ways to help our communities navigate the challenges of the COVID-19 pandemic. We contributed more than $18 million to aid relief efforts globally through monetary and supply donations and by providing engineering and manufacturing expertise and resources. This included donations of personal protective equipment (PPE) and medical equipment to local hospitals and government agencies.
At Boston Scientific, our work is guided by core values that define our culture and empower our employees, including Caring, Diversity, Global Collaboration, High Performance, Meaningful Innovation and Winning Spirt. As of December 31, 2020, we had approximately 38,000 employees. We believe the collective talent of our employees and our shared corporate culture and values gives us a competitive edge.
Boston Scientific operates in accordance with the United States Department of Labor and International Labour Organisation's (ILO) Core Conventions.
Commitment to Labor Initiatives or Standards
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.
Boston Scientific prohibits all forms of child labor as prohibited by the Unites States Department of Labor, Fair Labor Standards Act (FLSA) and ILO conventions C138 and C182 (Child Labor). Boston Scientific supports the rights of children to have access to education, healthcare, and protection from criminal behavior. Boston Scientific, in accordance with local labor laws, does not tolerate managers, contractors, or outside consultants who are found to be in violation of labor issues and such relationships may be terminated. We expect the same of our contractors, suppliers and business partners across the globe.
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 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 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.
Risk Assessment Related to Labor Issues
This aspect is addressed within Boston Scientific’s Global Compliance Program, discussed on our website in the Compliance and Ethics section.
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 in the Code of Conduct.
Freedom of Association
In the Spirit of Articles 17 and 20 of the Universal Declaration of Human Rights, among others, 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 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. The Code of Conduct is available in multiple languages to assure global employee access to this information.
Employee Health & Safety
Boston Scientific takes a global approach to prioritizing, executing and monitoring efforts to achieve EHS goals to help ensure employee safety and foster a safety-oriented culture in all of our offices and facilities. A commitment to employee health and safety is a prerequisite to our pursuit of patient care. A shared culture of ensuring the safety and health of our employees enables meaningful innovation and business success. As outlined in our Employee Health and Safety Policy, our strong health and safety performance contributes to competitive strength and benefits not only our employees, but also our customers, communities and shareholders.
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.
To ask questions or to report a concern about Boston Scientific’s adherence to human rights laws and labor standards, individuals may use Boston Scientific’s Advice Line. The BSC Advice Line handles calls 24/7 in multiple languages and may be accessed toll-free at 888-968-8425.
U.K. Modern Slavery Act Statement
For the Year Ended December 31, 2021
This statement (the “Statement”) of Boston Scientific Corporation for the year ended December 31, 2021 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 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.
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 2021, 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. Following the completion of the acquisition of BTG plc during 2019, we integrated 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 gynaecological 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 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 labour, 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.
This statement has been approved by the Board of Directors of Boston Scientific Corporation
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