Human Rights and Labor Standards Policy

Reviewed and adopted by the Board of Directors on 17 July 2026

1. CROSS REFERENCES TO THIS POLICY

1.1 Merit Code of Conduct: https://www.merit.com/wp-content/uploads/2025/08/2025-MMSI-CodeOfConduct-FINAL.pdf

1.2 UK Modern Slavery Act Statement: https://www.merit.com/compliance/uk-modern-slavery-act-statement/

1.3 California Transparency Act Statement: https://www.merit.com/compliance/california-transparency-act/

1.4 Code of Conduct for Suppliers: https://www.merit.com/compliance/code-of-conduct-for-suppliers/

1.5 Merit Conflict Minerals Policy: https://www.merit.com/compliance/conflict-minerals-policy/

2. ORGANIZATIONAL STRUCTURE AND OPERATIONS

Founded in 1987, Merit set out to build the world’s most customer-focused healthcare company by understanding customers’ needs and innovating and delivering a diverse range of products that improve the lives of people, families, and communities throughout the world.

Our products are used in the following clinical areas: radiology; diagnostic and interventional cardiology; interventional radiology; neurointerventional radiology; vascular, general and thoracic surgery; electrophysiology; cardiac rhythm management; interventional pulmonology; interventional nephrology; orthopedic spine surgery; interventional oncology; pain management; breast cancer surgery, outpatient access centers; intensive care; imaging; and interventional gastroenterology.

Merit maintains a diverse, multi-campus manufacturing footprint in North America, South America, Europe and Asia, with a global distribution network focused on delivering our products and technologies to our customers.

We are a global company with international operations, and we sell our products in countries throughout the world. We employ approximately 7,500 people in approximately 40 different countries. Details of Merit’s organization and company can be found on https://www.merit.com/investors/reports-statements/.

3. COMMITMENT TO HUMAN RIGHTS AND LABOR STANDARDS

Merit recognizes our obligation to provide our customers with high quality medical devices at a competitive price while seeking to ensure that no person in any part of the supply chain is exploited or treated in a way that violates relevant human rights, business ethics, and labor standards. We are aware of the responsibilities we bear to parties involved in producing our products and have developed this Human Rights and Labor Standards Policy (“Policy”) to outline the standards that we, and ultimately all stakeholders involved with the business, should seek to follow. Merit shall show a preference, where appropriate and legally permitted, to suppliers with higher labor standards.

Merit requires its employees, and suppliers of its medical device products, to adhere to this Policy. The scope of labor standards covered by the Policy includes standards relating to employees within Merit worldwide and workers within our global supply chains.

This Policy is designed to be used as a framework for Merit’s worldwide labor standards and should also be read together with Merit’s Global Code of Conduct, and Merit’s Supplier Code of Conduct, which apply to the entire Merit organization and all Merit suppliers.

Merit’s definition of “Human Trafficking” is the recruitment, transportation, transfer, harboring or receipt of persons, by means of the threat or use of force, fraud or other forms of coercion, including the giving or receiving of payments or benefits to obtain the consent of a person having control over another person, for the purpose of exploitation.

3.1 International Human Rights Law Framework

Merit commits to conducting our business in alignment with the objectives of the United Nations Guiding Principles on Business and Human Rights (“UNGPs”), the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, the International Covenant on Economic, Social and Cultural Rights, and the International Labour Organization Declaration on Fundamental Principles and Rights to Work, as well as the aspirations outlined in the United Nations Sustainable Development Goals.

Merit recognizes the diversity of laws in the locations where we operate and where people use our products and services. We respect local laws and, when faced with conflicts between these laws and our human rights commitments, we seek to honor the principles of internationally recognized human rights.

3.2 Scope

This Policy applies to all Merit employees, including management and executives, and Merit suppliers and business partners.

4. POLICY STATEMENT

MERIT’S MINIMUM LABOR STANDARDS ARE:

4.1 Child Labor: Merit will not tolerate the use of child labor. Our suppliers must engage workers whose age is the greater of: (i) 15 or (ii) the minimum age to work in the country where work is performed. Moreover, workers under the age of 18 must not perform hazardous work. Merit supports the development of legitimate workplace apprenticeship programs that comply with applicable laws and Merit’s Supplier Code of Conduct.

4.2 Involuntary Labor, Human Trafficking, and Slavery: Neither Merit nor its suppliers may use forced labor, including slave labor, prison labor, indentured labor, bonded labor, or similar practices. Our suppliers, and any entity supplying labor to them, must not traffic workers or in any other way exploit workers by means of threat, force, coercion, abduction, or fraud. Work must be voluntary, and workers must be free to leave work and terminate their employment or other work status with reasonable notice. Our suppliers must not require workers to surrender original government-issued identification, passports, or work permits as a condition of working, and our suppliers may only make copies of such documents to the extent reasonably necessary to complete legitimate administrative and immigration processing. Suppliers shall ensure that no employment fees or costs are borne in whole or in part by workers.

4.3 Safety and Health: Merit and suppliers shall provide a safe and healthy workplace environment and shall take effective steps to prevent potential accidents and injury to employees’ health by minimizing, so far as is reasonably practicable, and in cooperation with its employees, the hazards inherent in the workplace. All employees will receive safety and job-specific instructions during their employment with the company. Employees shall have access to clean sanitary facilities and drinking water. Responsibility for implementing the Health & Safety element of this Policy is assigned to the Global Head of Environmental Health & Safety and cascaded to the teams appointed in the regions and in respective country sites.

4.4 Wages and Benefits: Merit and our suppliers must pay their workers in a timely manner and provide compensation (including overtime pay and benefits) that, at a minimum, satisfy applicable laws. Merit and suppliers must provide their workers with the basis on which workers are being paid in a timely manner via pay stub or similar documentation. Deductions from wages as a disciplinary measure are not permitted.

4.5 Working Hours: Except in unusual or emergency situations, (i) Merit and its suppliers are committed to respecting reasonable working hours, ensuring that workers are not overburdened and have adequate rest, (ii) each worker must be entitled to at least one day off for every seven-day work period. In all circumstances, working hours must not exceed the maximum amount permitted by law.

4.6 Anti-Discrimination: Working conditions must be based on an individual’s ability to do the job, not on personal characteristics or beliefs. Merit and our suppliers must not discriminate on the basis of race, color, national origin, gender, sexual orientation, religion, disability, age, pregnancy, marital or family status, or similar factors in hiring and working practices such as job applications, promotions, job assignments, training, wages, benefits, and termination. Suppliers must not subject workers or applicants to unreasonable medical tests as a means of discriminating against them.

4.7 Fair Treatment: All workers must be treated with respect and dignity. Merit and our suppliers must not engage in or permit physical, verbal, or psychological abuse. Merit and suppliers must also not engage in coercion, including threats of violence, sexual harassment, or any practice that restricts or controls workers’ freedom to enter or exit work sites or employer provided housing. Workers must be free to voice their concerns to Merit or its auditors, and allowed to participate in the Merit audit process, without fear of retaliation by supplier management.

4.8 Immigration Compliance: Merit and our suppliers may only engage workers who have a legal right to work. If Merit or suppliers engage foreign or migrant workers, such workers must be engaged in full compliance with the immigration and labor laws of the host country.

4.9 Freedom of Association: Merit and our suppliers must respect the rights of workers to establish and join a legal organization of their own selection. Workers may not be penalized or subjected to harassment of intimidation for the non-violent exercise of their right to join or refrain from joining such legal organizations.

MERIT’S MINIMUM BUSINESS ETHICS ARE:

4.10 No Bribery: Merit and our suppliers must not offer nor accept bribes or other means of obtaining undue or improper advantages to anyone for any reason, whether in dealings with governments or the private sector. Our suppliers must not induce Merit employees to violate our Code of Business Conduct and Ethics.

4.11 Anti-Corruption: Merit and its suppliers must comply with applicable anti-corruption laws, including but not limited to the United States Foreign Corrupt Practices Act (FCPA), the EU Anti-Corruption Directive (Directive 2026/1021)), and the United Kingdom Bribery Act 2010, and not offer anything of value, either directly or indirectly, to government officials to obtain or retain business. Merit and our suppliers must not make illegal payments to government officials themselves or through a third party. Suppliers who are conducting business with the government officials of any country must follow Merit’s policies on the law governing payments and gifts to governmental officials.

4.12 Whistleblower Protections: Merit and our suppliers must protect worker whistleblower confidentiality and prohibit retaliation against workers who report workplace grievances. Suppliers must create a mechanism for workers to submit their grievances anonymously.

5. MANAGEMENT REPRESENTATIVE

Merit senior management is committed to supporting this Policy and the associated Labor Standards Assurance System (“LSAS”). The Management Representative assigned the responsibility for implementing an effective LSAS is Merit’s Chief Operating Officer.
The responsibilities of the Management Representative are as follows:

• Develop procedures to meet Policy requirements
• Communicate labor standards issues to senior management
• Oversee communication with suppliers pursuant to labor standard status reviews and to implement a plan of action to meet objectives
• Set objectives for labor standards assurance with plans for training, auditing and required action
• Regularly review, update, and improve this Policy
• Implement training for staff involved with the LSAS

6. ROLES AND RESPONSIBILITIES

Given the size of Merit and the number of companies in the supply chain, Merit’s Global Procurement department will assume the main responsibility of the LSAS, including its operational details, and will be assisted by the Vice President, Environment, Social & Governance, the Chief Compliance Officer and the Chief Human Resources Officer. The Management Representative shall consult with the Vice President, Global Strategic Sourcing to develop the LSAS and present any developments at regular intervals to senior management. Resources relating to the LSAS will be available to all appropriate staff.

7. LABOR STANDARDS STATUS REVIEW FOR SUPPLIERS

Merit commits to undertaking a Labor Standards status review when contracting with a new supplier and periodically thereafter to encourage labor standards throughout our supply chain that are satisfactory and continually improving. We recognize that if any contractor or sub-contractor were found to be using unethical or illegal labor programs, this would have a profound impact on the reputation and integrity of Merit. The following Supplier Mapping and Assessment Process table outlines the steps to be taken by Merit for each in-scope supplier. Merit may choose to engage a third-party partner to assist in the following actions.

MERIT’S SUPPLIER MAPPING AND RISK ASSESSMENT PROCESS

8. LEGAL REQUIREMENTS

Merit commits to remain up to date with changes to relevant employment legislation using its in-house Legal Department, its Compliance Department, its Human Resources Department, outside counsel, and other resources, including legal subscriptions, client newsletters, and labor-related blogs.

Relevant employment legislation involving Merit’s direct operations in the United States, Europe, China and Mexico is outlined in Merit’s Employee Handbook (modified by region) and is available to all employees in those locations. Employees working in other locations that have joined Merit via acquisitions are governed by the legacy employee handbooks of their predecessor companies, until they undergo transition to Merit handbooks. Government-issued employment law notices, advising employees of certain rights, are also required to be posted in Merit locations in the United States and other jurisdictions.

9. OBJECTIVE, TARGETS AND PROGRAMS

The success of Merit’s LSAS will depend on its ability to assign the appropriate risk rating to each of its suppliers (Low Risk, Medium Risk and High Risk), diligently monitor suppliers during their respective supplier improvement plans, and encourage or require suppliers to continually improve.  An overview of the LSAS risk assessment and monitoring process is as follows:

A LSCAR will follow the risk rating of those medium or high-risk suppliers that require correction. Merit’s long-term objective is to have only low-risk suppliers or a small minority of medium-risk suppliers that are earnestly addressing non-conformity outlined in LSCAR to become assessed as low-risk.

9.1 Competence, training and awareness

Merit commits to the annual training of relevant staff to be competent with handling and administering the labor standards program. Relevant staff for Merit are those involved in procurement, human resources, and plant managers, as well as identified personnel in Operations. People involved with the LSAS should:

• Have a good understanding of how Merit operates, with knowledge of the supply chain
• Be in a position to contact suppliers and build a relationship with them
• Be trained in the LSAS requirements

Training for the LSAS is implemented either in live courses, or as part of the Merit Medical University online training platform (or any successor learning management system), which tracks each enrolled employee’s required courses, test scores (if any), and completion dates. When a particular policy or document is revised, those employees assigned to review, acknowledge and accept such documents are required to read and acknowledge that they have been trained to the current document revision.

9.2 COMMUNICATIONS

Merit will continue using our Oracle database for storing and updating supplier contacts, identifying those that are in scope, and communicating with them with respect to labor standards, business ethics, and other Corporate Social Responsibility (CSR) matters. 

Merit shall receive and respond to allegations, complaints or other alerts about labor standards issues as part of our established whistle-blowing procedures, which provides complainants with the option of reporting or complaining anonymously. See https://merit.alertline.com/gcs/welcome or call +1 (877) 874-8416.

9.3 DOCUMENTATION AND RECORDS

Documentation and records in relation to the LSAS shall be kept using standard document and record keeping procedures in line with other Quality Documents and Merit’s Record Management Policy. A copy of this Policy shall be communicated via email to all relevant Merit employees (i.e., Purchasing, Human Resources, Merit plant managers) and posted at:  https://www.merit.com/compliance/human-rights-and-labor-standards-policy/

9.4 OPERATIONAL CONTROL AND SUPPLY CHAIN MANAGEMENT

For the direct operation of the company, the relevant Employee Handbook (as modified by region) and related policies document the procedures involved with controlling the labor standards of Merit and addressing risks or breaches of this Policy that may be posed.

For management of the supply chain, the senior management of Merit have identified two critical control points for labor standards: Supplier Approval and Supplier Assessments.

Merit commits to monitoring and maintaining labor standards in its supply chain through the distribution and communication of the company’s labor standards policies along with the ongoing assessment of whether these standards are met. This will occur using assessments at a supplier’s onboarding and during its annual review. New suppliers must meet Merit’s initial approval that outlines the standards the supplier is expected to meet as part of its contract or, in the absence of a commercial agreement, its acceptance of a Merit Purchase Order (PO).

Reviews may also occur during visits to suppliers to ensure they continue to comply fully with the Code of Conduct for Suppliers and this Policy. The findings of supplier visits shall be noted in the LSAS.

9.5 EMERGENCY RESPONSE TO CRITICAL ISSUES

Merit has identified aspects of this Policy that are of particular importance for meeting minimum levels of labor standards. Sections 3 and 4 are regarded by Senior Management of Merit as statements, the breach of which is considered a critical issue that justifies an emergency response. Any critical issue identified will generate an LSCAR, followed by supplier providing a written CA/PA Plan within 14 days, which will then be approved by all parties involved.

Should the supplier fail to deliver a written CA/PA Plan or the supplier’s plan does not correct the critical issue noted, then the termination of such supplier, and the process of re-sourcing of product from within Merit’s existing supplier base (which may take several months) shall begin within 30 days of the initial breach of the above minimum labor standards.

9.6 PERFORMANCE MONITORING AND MEASUREMENT

Merit commits to monitoring the performance of suppliers against the LSAS, annually assessing the progress of the program, and setting relevant targets, in addition to those stipulated in this Policy, to ensure the progression of the LSAS against our objectives. Progress of parties in the supply chain shall be measured against the level of compliance with the standards set forth in the SAQ and, if appropriate, updating the SAQ and Code of Conduct for Suppliers to express an expectation of improvement in labor and ethical standards consistent with internationally recognized norms. Merit’s risk assessment and monitoring process is outlined in sections 7 and 9 above.

9.7 CORRECTIVE ACTION

Merit’s LSAS will be used to document improvements relative to labor standards and business ethics. Where issues are identified or where there is a risk of non-compliance to the Supplier Code of Conduct or this Policy, the supplier will be required to take action to ensure that the risk is mitigated and any identified issues are remediated as effectively as possible.

The areas identified as a labor standards risk, e.g., deviation from Merit’s minimum labor standards, will be communicated to the supplier via an LSCAR. This should include the reason for determining risk (e.g., failure to provide evidence of compliance against a particular policy requirement), and a level of priority for remediation if there is more than one.

Merit will thereafter require the supplier to provide a realistic corrective action plan—through an LSCAR—detailing how the issue will be corrected by the date provided. It will then be Merit’s responsibility to seek evidence of correction. Where it is not offered freely by the supplier, it will be followed up by the LSAS representative or relevant buyer.

Once correction is complete and there are no outstanding issues, supplier may move on to the Low-Risk Supplier Improvement Plan (annual review and expectations letter) and be monitored accordingly.

9.8 MANAGEMENT REVIEW

Senior management will formally review the labor standards program at planned intervals to ensure its continuing suitability, adequacy and effectiveness, typically on an annual basis.