Statement on Slavery and Human Trafficking for 2017

STERIS plc and its Board of Directors strongly oppose all forms of slavery, servitude, forced labor and human trafficking ("Slavery and Human Trafficking"). This Statement is made pursuant to the Modern Slavery Act of 2015 (“Act”) and sets out the steps that STERIS plc (together with all of its direct and indirect wholly-owned subsidiaries, the “Company” or “STERIS”) have taken to prevent modern Slavery and Human Trafficking in its business and supply chains in 2017. The Company recognizes that Slavery and Human Trafficking can occur in many forms. References in this Statement to "Slavery and Human Trafficking" are intended to encompass any form of coerced labor.

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 surgical tables, and connectivity solutions such as operating room integration; consumable products, such as detergents, gastrointestinal endoscopy accessories, barrier product solutions, and other products and services, including: equipment installation and maintenance, microbial reduction of medical devices, instrument and scope repair solutions, laboratory testing services, and on-site and off-site reprocessing. STERIS manufactures, sources, and provides services and solutions to its Customers globally. The Company’s supply chains are extensive and global, including thousands of suppliers.

The Company is committed to implementing and maintaining systems and processes to avoid complicity in Slavery and Human Trafficking related to our operations and those of our affiliate commercial organizations, 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") and the Code is reviewed and updated as needed every other year. 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 requires all employees, among other obligations, to act lawfully, ethically, and responsibly in all of their business practices, and comply with applicable laws.

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. The Code also provides for communication channels to be utilized in case of any violations including the Company's Global Compliance, Human Resources, Audit and Legal Departments. To further encourage compliance and the reporting of violations, the Company maintains an Integrity Helpline (reporting system) and website. 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 the Company's Board of Directors. STERIS has not received any reports with respect to our businesses regarding Slavery or Human Trafficking.

The Company has no reason to believe that any Slavery or Human Trafficking is occurring in any of the Company's businesses. Nonetheless, during 2017, the Company has taken the following steps to detect and prevent any violations of the Act or conditions that may give rise to a violation of the Act:

  • A dedicated Global Compliance function (“Compliance”) was established and staffed at STERIS. Among other things, it is the responsibility of Compliance to effect and maintain business processes, employee and supplier training programs, and vigilant monitoring, to ensure adherence to the Act.
  • A specific Policy on Modern Slavery and Human Trafficking (the “Policy”) has been prepared by management and communicated to all employees in 2017.
  • A Supplier Code of Conduct defining requirements and expectations for ethical behavior by its suppliers and business partners, and requiring compliance with applicable laws including the Act has been adopted and appears prominently on the STERIS internet site for viewing by the Company’s suppliers and business partners. 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 has assessed its internal labor practices 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 the Act.
  • The Company has conducted due diligence in the form of a survey of its largest suppliers inquiring as to their labor practices, recruiting methods, treatment of employees and contractors, and general human rights obligations. Replies to those surveys were reviewed and follow up to non-conforming responses is proceeding to ensure full compliance with the Act. The Company reserves the right to audit its supply chain as appropriate. The Company’s network of suppliers and sub-suppliers, given its fragmented and inherently opaque 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 the assurance of compliance.
  • The Company has prepared training materials for its employees to increase awareness of issues surrounding Modern Slavery and Human Trafficking while specifically identifying signs and conditions typically associated with violations of the Act. The training materials have been communicated to employees coincident with the release of the new Policy.
  • Training and education materials focusing on Modern Slavery and Human Trafficking, including the stated obligations of both the Company and its supply chain partners, has been prepared and are made available to suppliers when surveyed.

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

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

 

Signed:        Date: September 27, 2017
                  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