Arthrex is a global leader in new product development and medical education in orthopedics and we are committed to one mission: Helping Surgeons Treat Their Patients Better™. Arthrex is headquartered in Naples, Florida, with subsidiaries around the world. Approximately 85% of Arthrex’s products are made in the United States. The top six countries from which goods, services or materials are sourced outside the U.S. are: Germany, Switzerland, Israel, Netherlands, Italy and Taiwan. Arthrex is committed to doing business ethically and responsibly and will only work with companies that share that commitment.

The California Transparency in Supply Chains Act and the UK Modern Slavery Act require companies doing business in those jurisdictions to disclose their efforts to eradicate slavery and human trafficking from their supply chains. Arthrex enthusiastically joins the fight to end forced labor and disclose the efforts we have undertaken to ensure that our supply chain is free from such abhorrent practices.

Policies:

As part of an ongoing initiative to identify and mitigate risks, Arthrex continuously works to further improve its policies and practices to ensure materials and services provided to Arthrex are procured only from suppliers who share this same level of commitment.

In 2019, Arthrex updated its Global Code of Conduct, strengthening its commitment to corporate responsibility and giving clear guidance on key expectations including human rights and modern slavery. The updated Global Code of Conduct was launched at the end of 2019 and is available in 18 languages. In 2020, Arthrex adopted the Global Policy on Human Rights that prohibits the use of slavery and human trafficking in Arthrex facilities and by suppliers in Arthrex’s supply chain.

Arthrex also provides several communication channels for reporting concerns or violations in good faith, including but not limited to the Arthrex Ethics Helpline.

Verification/Due Diligence:

Arthrex is committed to fair labor practices within its supply chain and expects its suppliers to meet these expectations. As such, Arthrex conducts a supplier survey to assess risk related to slavery, human trafficking and other human rights, and to identify areas for suppliers to implement effective controls. The company continues to enhance due diligence related to suppliers by integrating controls into the existing Third-Party Risk Management process. As necessary, Arthrex may use a third party to investigate the background of potential new suppliers to assess the risk of noncompliance with laws, including those related to slavery, human trafficking and other human rights.

Audits:

Arthrex monitors supplier behavior and compliance through announced routine audits to improve visibility, leverage and oversight of our supply chain. As part of these audits our suppliers are reviewed on implementation of policies prohibiting all forms of human trafficking and forced labor. The company currently focuses its efforts on high risk suppliers, determined by various risk factors including but not limited to supplier location and propensity for utilization of slavery, human trafficking or forced labor.

Certification:

To ensure our suppliers respect and enforce company standards, Arthrex suppliers are required to sign a Master Supply Agreement (MSA) that mandates compliance with the Arthrex Code of Conduct, and all applicable laws in their respective countries, including but not limited to, laws regarding human rights, forced labor and human trafficking. The company is working to ensure all high-risk suppliers have entered into an MSA. For suppliers not required to sign an MSA, Arthrex’s Purchase Order Terms and Conditions require suppliers to certify that materials or items supplied to Arthrex were not manufactured from or with child, forced, or prison labor.

Accountability:

Arthrex maintains internal accountability standards and procedures applicable to both employees and suppliers who fail to meet company standards. The company provides channels for employees and third parties to report potential non-compliance and has procedures in place for investigating, substantiating and remediating reports of potential human rights violations. In 2021, Arthrex implemented a new procedure that sets forth Arthrex’s worldwide process for managing human rights reports that may come through these reporting channels, including guidance for the analysis and review of potential noncompliance. This procedure expands on the Global Policy on Human Rights. Where noncompliance is identified, a corrective action plan, up to and including termination, is put in place.

Training:

All employees are expected to read and sign the Global Human Rights policy to increase awareness of the risk associated with slavery, human trafficking and human rights. In addition, employees with direct responsibility for supply chain management receive specific training focused on identification and risk mitigation of slavery, human trafficking, and other human rights within the supply chain. The company routinely reviews policies to ensure content is up-to-date and training has been successfully completed.

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