The Modern Slavery Act 2015 (“the Act”) came into effect from 29 October 2015 and requires certain businesses to disclose information regarding the steps, if any, they have taken to ensure slavery and human trafficking are not taking place within their supply chain as well as within their own organization during the previous financial year. As a multi-national corporation, Merit Medical Systems, Inc., including its subsidiaries (“Merit”), is committed to good corporate citizenship and the highest ethical standards.
Merit’s Organization, Products and Supply Chain
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.
Merit’s primary products consist of inflation devices used in angioplasty and stent placement; diagnostic and therapeutic catheters used for various procedures in cardiology and radiology; diagnostic and hydrophilic products used to manage and monitor the administration of contrast media and other fluid solutions; thrombolytic catheters and fluid dispensing systems; embolotherapeutic products for the treatment of uterine fibroids, hypervascularised tumours, and arteriovenous malformations; and vertebral augmentation and related procedures; and procedural trays, packs, and kits.
Merit maintains a diverse, multi-campus manufacturing footprint in North America, Europe, and Asia, with a global distribution network focused on delivering our products and technologies to our customers.
We have customers in approximately 123 countries, employ approximately 4600 people globally (of whom approximately 360 are in our Supply Chain) and have approximately 1,749 suppliers. Details of Merit’s organization and company can be found on https://www.merit.com/investors/annual-report-and-proxy/.
Merit’s Policies and Business Operations
Merit has a comprehensive Code of Conduct for Suppliers, Code of Business Conduct and Ethics, and Global Compliance Policy, and is committed to ensuring that our global operations comply with our internal policies relating to human rights as well as with any legal requirements, such as the UK Modern Slavery Act 2015 and the California Transparency in Supply Chains Act.
Merit works to continually improve its processes of verification, audit, certification, internal accountability, and training to assess and ensure that suppliers comply with Merit’s policies and expectations to respect human rights. We engage third-party providers to help with our efforts to promote improvement in this area while retaining management of internal controls and training.
As a leading medical device company, Merit provides products and technology that make healthcare safer while reducing costs. In the UK, the sourcing and procurement organization delivers value by establishing global partnerships and developing new service solutions with our manufacturer suppliers focused on our patient-focused products. We work with global suppliers across different fields including businesses with operations in US, Europe, and Asia.
Prior to approving suppliers for use, Merit 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.
Controls and Audits
Merit audits its suppliers periodically. Merit utilizes a supplier survey and audit schedule to promote suppliers’ compliance with Merit’s supplier performance and quality expectations. Supplier surveys 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 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. Additionally, through Merit’s annual supplier due diligence relative to conflict minerals regulations in the United States (as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010), Merit conducts country-of-origin inquiries regarding the origin of certain minerals.https://www.merit.com/about/conflict-minerals-report/
Communication and Internal Accountability
All Merit employees, directors and agents are held accountable for adhering to 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 UK Modern Slavery Act and the California Transparency in Supply Chains Act.
Merit will promptly investigate any allegations of non-compliance. Violations of Merit’s Code of Business Conduct and Ethics may result in disciplinary action, including termination of employment or agreement.
Our respective policies and codes of conduct provide important guidelines for our interactions with customers, suppliers and other business partners, and one another. Our colleagues are encouraged to raise concerns; this includes violations of our code(s) of conduct, our company policies, and the laws of the countries in which we operate. We have sophisticated reporting mechanisms in place to collect and relay information regarding potential violations to appropriate company resources for review and follow up action.
Modern slavery and human trafficking has Merit’s attention and going forward it is Merit’s aim to eradicate modern slavery from its business and supply chain. Merit recognizes that eradication of modern slavery is an ongoing and evolving process. Merit will share its progress through its annual statements.
*This statement was approved by the Board of Directors on 21 July, 2017.
Name: Fred Lampropoulos, Chairman of the Board of Directors and CEO
Date: 21 July, 2017