STERIS plc (the "Company") and its Board of Directors strongly oppose all forms of slavery, servitude, forced labor and human trafficking ("Slavery and Human Trafficking"). 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 affiliates, as well as any such activity occurring within our supply chains or the supply chains of our affiliates. This Statement is made pursuant to the Modern Slavery Act of 2015 ("Act"). This statement applies to the Company and all of its direct and indirect wholly-owned subsidiaries. The Company recognizes that Slavery and Human Trafficking can occur in many forms. References in this Report to "Slavery and Human Trafficking" are intended to encompass any form of coerced labor.
The Company was formed in the fall of 2014 but did not become an active entity until November 2, 2015, when it completed its combination (the "Combination") with STERIS Corporation ("Old STERIS"), which was in effect STERIS plc's predecessor, and with Synergy Health plc. Because the Combination occurred in the second half of the fiscal year, and during that period (and continuing through the present) much of the Company's efforts were occupied with integration efforts relating to the Combination, the Company took no specific steps during fiscal 2016 to ensure that Slavery and Human Trafficking were not taking part in its supply chains or business, except as noted below.
The Company has maintained a Code of Business Conduct ("Code") since the date of the Combination. A similar Code of Conduct applied to Old STERIS prior to the Combination. The Company requires all employees to read and understand the Code and conducts periodic training of all employees with respect to the Code.
The Code requires all employees of the Company and all of its subsidiaries, among other obligations, to:
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 channels to be utilized in case of any violations including the Company's Human Resources, Audit and Legal Departments. To further encourage compliance and the reporting of violations, the Company maintains an Integrity Helpline and an Integrity Website. No reprisals are made with respect to reported matters, and reports may be made anonymously. All reports are regularly reviewed by a senior compliance official with the Audit Committee of the Company's Board of Directors. We have not received any reports with respect to our businesses regarding Slavery or Human Trafficking.
Based upon the foregoing and other considerations, the Company has no reason to believe that any Slavery or Human Trafficking is occurring in any of the Company's businesses. Nonetheless, during the second half of fiscal 2017, the Company intends to begin developing appropriate and effective responses to Slavery and Human Trafficking. This will include responses within all segments of the Company's business, including those businesses and subsidiaries not in the UK or not subject to the Act.
Among other actions, the Company intends to assess the status of the engagement of labor through recruiters and the hiring of temporary employees in the Company's Asian and South American operations; the Company is of the opinion that in these portions of the world there is a greater risk of Slavery and Human Trafficking. The Company will also conduct training of management and supervisory employees with respect to Slavery and Human Trafficking.
With respect to the Company's supply chains and suppliers, the Company will also undertake or consider undertaking the following actions:
The Company will not work with any organization which we find to be knowingly involved with Slavery or Human Trafficking. We encourage anyone, 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 shall be responsible for ensuring that the activities of the Company and its subsidiaries comply with the Act. To this end, the Company will provide adequate resources, training and investment to ensure its successful application.
Signed: Date: August 2, 2016
Walter M Rosebrough, Jr.
President, CEO and Director