California Supply Chains Act

California Supply Chains Act

ConvaTec is committed to fair employment practices and to following applicable employment law wherever it has operations. This includes complying with laws that prohibit child or forced labor.  In 2016 ConvaTec initiated a program to review its existing policies, procedures and approach to supply chain transparency and modern slavery, both within its internal operations and third party suppliers.  This cross-functional project has made steps in assessing the labor risk within the supply chain and adopting policies and processes to ensure compliance with globally-recognized standards.  The program is subject to continuous improvement and ConvaTec is committed to providing the resources necessary to achieve year on year enhancements in the management of labor risks in its global supply chain.
 
The current status of the program is summarized below:   

1. Verification

ConvaTec evaluates prospective suppliers through a business review focused on the quality of the product manufactured, the standard of documentation in place and other performance indicators.  We do not currently engage in the verification of all parties in the product supply chain to evaluate and address risks of human trafficking and slavery but initial steps have been taken to generate a global heat map for labor risks.  Work on extending the on-going management and review of suppliers to include verification of human rights and labor standards is underway by use of a supplier self-assessment questionnaire. We do not use third-party verifiers.

 

2. Audits

ConvaTec is currently deploying audit programs of its suppliers in a phased risk-based approach to evaluate supplier compliance with company standards for trafficking and slavery in supply chains.  ConvaTec has introduced a Supplier Code of Conduct (“Supplier Code”) to address issues of human rights and the prohibition of child labor, compulsory labor and human trafficking. Under the Supplier Code, ConvaTec may perform on-site assessments to monitor the supplier’s compliance.  Where the supplier has failed to comply with the Supplier Code, ConvaTec shall put in place a remediation plan or in cases of severe non-compliance, ConvaTec may terminate the relationship. 

3. Certification

ConvaTec requires its direct suppliers to comply with the laws of the country in which they operate. To ensure our suppliers respect and enforce our standards with regard to anti-slavery and human trafficking we have re-drafted the relevant clause in our supplier agreements to read as follows:

”Supplier represents, warrants and covenants that (i) it complies with all applicable laws on working hours and employment rights in the countries in which it operates; (ii) the evaluation and treatment of its employees and applicants for employment are free from discrimination and harassment, whether such discrimination or harassment is based on sex, age, race, color, ancestry, religion, belief, disability, sexual orientation or marital status; (iii) the Products supplied under this Agreement shall be manufactured under conditions in compliance with the principles set out in the International Labour Organization Eight Fundamental Conventions nos. 29, 87, 98, 100, 105, 111, 138 and 182 and in the United Nations Convention of the Rights of the Child Article 32; and (iv) no Products have been made in whole or in part by sweatshop labour, convict labour or indentured labour under penal sanction. “

This clause is not yet standard in all our supplier contracts, but is being phased in as ConvaTec enters into contracts with new suppliers and/or renews contracts with existing suppliers.

4. Internal Accountability

ConvaTec maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and human trafficking.
The ConvaTec Code of Ethics and Business Conduct (“Code of Ethics”) covers workplace issues including human rights, discrimination and harassment.  The ConvaTec Human Rights and Labor Standards Policy (“Policy”) specifically addresses the United Nations Universal Declaration on Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work and the Ten Principles of the United Nations Global Compact. Each ConvaTec employee is required to report any actual or potential violation of either the Code of Ethics or the Policy and communication channels are in place within the company to facilitate and encourage such reporting. 

5. Training

ConvaTec provides training on the Code of Ethics for all new and existing employees on an annual basis.  In 2016 over 1,300 employees completed online training on the Human Rights and Labor Standards Policy.