California Transparency Act

California Transparency in Supply Chain Act

On September 30, 2010 SB 657, “The California Transparency in Supply Chains Act of 2010” was signed into law, for the purpose of eliminating the existence of products sold in California that are made with slave labor at any point in the supply chain. The Act requires certain businesses to disclose the extent and efforts taken to eradicate slavery and human trafficking from each business’ supply chain.

Supplier Approval

Prior to approving suppliers for use, Merit Medical evaluates suppliers for suitability as a Merit business partner. Supplier approval activities are based on risk and may include supplier surveys and on-site audits of supplier facilities. On-site supplier audits are conducted by Merit employees and do not specifically include assessment for human trafficking and slavery activity.

Supplier Controls

Merit Medical utilizes a supplier survey and audit schedule to confirm suppliers’ compliance with Merit’s supplier performance and quality expectations. Supplier survey and audits are performed by Merit employees and do not specifically include assessment for human trafficking and slavery activity. The frequency of supplier surveys and audits is based upon supplier risk and supplier performance.

Merit Medical generally utilizes supply agreements, quality agreements and/or purchase order terms and conditions for controlling relationships with suppliers. These agreements include commitments for suppliers to comply with laws and regulations applicable to the service or material provided by the supplier.

Supplier Performance Monitoring

Merit Medical monitors the on-going supplier performance of approved suppliers through several mechanisms, which may include conformance with supplier agreements (including purchase orders, supply agreements and quality agreements), product quality, financial health, and general business practices and performance. The type and frequency of supplier performance monitoring is based on supplier risk.

Supplier Communication

All Merit employees are expected to follow Merit’s Code of Business Conduct and Ethics in all aspects of business, including dealings with suppliers. Employees involved in Purchasing and Supplier Management functions may also be trained on specific responsibilities regarding The California Transparency in Supply Chains Act.