Statement on Human Trafficking and Slavery for 2018

STERIS plc and its Board of Directors strongly oppose all forms of slavery, servitude, forced labor, child labor and human trafficking. The Company recognizes that human trafficking and slavery can occur in many forms. References in this Statement to "human trafficking and slavery" are intended to encompass any form of coerced labor. This Statement sets out the steps that STERIS plc (and with its direct and indirect wholly-owned subsidiaries collectively the "Company" or "STERIS") have taken to prevent human trafficking and slavery in their businesses and supply chains in fiscal 2018.

STERIS is a leading provider of infection prevention and other procedural products and services. STERIS's mission is to help its Customers create a healthier and safer world by providing innovative healthcare and life science product and service solutions around the globe. STERIS offers its Customers a unique mix of innovative capital equipment products, such as sterilizers and washers, surgical tables, lights and equipment management systems and connectivity solutions such as operating room integration; consumable products such as detergents and gastrointestinal endoscopy accessories and other products; services, including equipment installation and maintenance, microbial reduction of medical devices, instrument and scope repair solutions, laboratory services and outsourced reprocessing. STERIS manufactures, sources, and provides services and solutions to its Customers globally. The Company's supply chains include thousands of suppliers and are extensive and complex.

The Company has implemented and maintains systems and processes to avoid complicity in human trafficking and slavery related to our operations and those of our affiliates and subsidiaries, as well as any such activity occurring within our supply chains or the supply chains of our affiliates.

The Company maintains a Code of Business Conduct ("Code"), which requires all employees, among other obligations, to act lawfully, ethically, and responsibly in all of their business practices, and to comply with applicable laws. New employees are required to acknowledge their understanding of the Code and commit to adhering to the Code's policies. The Company requires all employees to participate in a training program every other year and to attest to their understanding of, and adherence to, the Code.

The Code also specifically provides that a failure by any employee to comply with laws or regulations governing the Company's business or the Code may result in disciplinary action, termination, and if warranted, legal proceedings, and provides for communication channels to be utilized in case of any violations. To further encourage compliance and the reporting of violations, the Company maintains an Integrity Helpline (reporting system) and website, available to employees as well as Customers, suppliers and all other business partners of STERIS. A strict anti-retaliation policy is followed, and reports may be made anonymously. All reports are promptly addressed by the Company's ethics committee and reviewed each quarter by the Compliance Committee of STERIS plc's Board of Directors. STERIS has not received any reports with respect to our businesses regarding human trafficking or slavery.

The Company has no reason to believe that any human trafficking or slavery is occurring in any of the Company's businesses. Nonetheless, the Company has taken the following steps to detect and prevent any violations of applicable human trafficking and slavery laws or conditions that may give rise to a violation:

  • A dedicated Global Compliance team is responsible for effecting and maintaining business processes, employee and supplier training programs, and vigilant monitoring, to ensure adherence to applicable human trafficking and slavery laws.
  • STERIS is working with a third-party provider to identify and address risks of modern slavery, especially throughout its global supply chain. The Company is using a Slavery & Trafficking Risk Template ("STRT") to survey its suppliers for risk of human trafficking and slavery. The STRT engages suppliers in the risk assessment process and, in doing so, helps STERIS foster constructive dialogue and raise supplier awareness of its commitment to tackling modern slavery risk. Furthermore, STERIS is a member of the STRT Development Committee.
  • Training and education materials focusing on human trafficking and slavery, including stated obligations of both the Company and its supply chain partners, have been made available to suppliers in conjunction with the surveys.
  • The Company reserves the right to audit its supply chain as appropriate. The Company's network of suppliers and sub-suppliers, given its fragmented nature, offers a relatively higher risk of exposure to violations. STERIS's continued and increasingly vigilant engagement with its supply base will enhance transparency and assist in compliance with the applicable human trafficking and slavery laws.
  • A Company-adopted Policy on Human Trafficking and Slavery (the "Policy") has been communicated to all employees and expressly prohibits human trafficking or slavery in any form. The Policy includes examples of specific practices that are prohibited and can be found by employees on the STERIS intranet.
  • A Supplier Code of Conduct defining requirements and expectations for ethical behavior by the Company's suppliers and business partners, and requiring compliance with applicable laws, including human trafficking and slavery laws, appears prominently on the STERIS internet site for viewing by the Company's suppliers. STERIS suppliers found to be in violation of the Supplier Code of Conduct are subject to disciplinary action, up to and including termination of the business relationship.
  • The Company assessed its internal labor practices in 2018 by surveying operations in Europe, Latin America, and Asia, including, but not limited to, any practices involving the engagement of labor through recruiters and the hiring of temporary employees. The internal assessment indicated compliance with applicable human trafficking and slavery laws.
  • The Company has prepared training materials for its employees to increase awareness of issues surrounding human trafficking and slavery while specifically identifying signs and conditions typically associated with violations of applicable human trafficking and slavery laws. The training materials were communicated to employees concurrently with the release of the Policy.

The Company will not work with any organization it finds to be knowingly involved with human trafficking or slavery. STERIS encourages everyone, including employees, contractors and suppliers, to report in good faith any issues or concerns regarding human trafficking or slavery.

The STERIS plc Directors and Senior Management are responsible for ensuring that the activities of the Company continue to comply with applicable human trafficking and slavery laws. To this end, STERIS will continue to provide adequate resources, the commitment of its employees, training, and investment to ensure compliance.

 

Signed:        Date: September 25, 2018
                  Walter M Rosebrough, Jr.
                  President, CEO and Director

 

 
STERIS Corporation

STERIS is a leading provider of infection prevention
and other procedural products and services.

5960 Heisley Road, Mentor, OH 44060 U.S.A.

800.548.4873 or 440.354.2600

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Registered in England and Wales No. 09257343.
Registered office: Rutherford House, Stephensons Way,
Derby DE21 6LY, United Kingdom