Introduction

Teleflex is committed to ensuring that Teleflex’s business and supply chain adheres to the highest standards of conduct, including compliance with all anti-slavery and human trafficking laws. We recognize that slavery and human trafficking is a real concern and will work hard to improve and enforce effective systems and controls to ensure any instances are detected and dealt with in our business or supply chain.

Teleflex is committed to ensuring compliance to recognized standards that have been established by organizations such as the International Labour Organization (ILO), the U.S. Department of Labor, the U.K. Modern Slavery Act 2015, The Ethical Trade Initiative (ETI) Base Code and the Responsible Minerals Initiative among others. Teleflex shall commit to continuous improvement in an effort to achieve full compliance to the standards within its own facilities as well as its supply chain. Teleflex is committed to meeting and ultimately exceeding the minimum standards as outlined in this policy and related procedure.

Additional information regarding the company structure, financials, the supply chain can be found within the company Global Impact Report on our CSR webpage (https://www.teleflex.com/usa/en/about-us/csr/index.html)

Our Structure

Teleflex is a global provider of medical technology products that enhance clinical benefits, improve patient and provider safety and reduce total procedural costs. To achieve this mission, Teleflex is committed to the following: investing in technology and developing our pipeline; leveraging and building our core franchises and distribution channels; attracting, developing and retaining talented employees around the world; and continuing to build financial strength by expanding our margins and maintaining strong cash flow all in an effort to successfully grow our reputation as a solid investment and a profitable, strong employer.

We primarily design, develop, manufacture and supply single-use medical devices used by hospitals and healthcare providers for standard diagnostic and therapeutic procedures in critical care and surgical applications. We sell our products to hospitals and healthcare providers worldwide through a combination of our direct sales force and distributors. Our products are used in a wide variety of markets and are not dependent upon any one end-market or procedure.

Our Supply Chains

The primary sources of the materials we procure are from Tier One providers that are thoroughly vetted by the Global Procurement and the Global Supply Quality teams. A tier 1 supplier to Teleflex is a manufacturer who provides products/services directly to Teleflex without dealing with other manufacturers upstream in the supply chain.

Most of these products are located in countries where the risk of modern slavery and human trafficking is low. For the countries from which we source materials where there is a higher risk, we ensure robust controls are in place when onboarding the supplier through our standard supplier vetting process and our LSAS and Supplier Anti-Corruption assessments and agreements.

Analysis and mapping of our supply chain show a large and complex chain with contract manufacturers, own site manufacturing, and raw material suppliers; however, the chain is linear, and there are no circular flows of materials or sub-components.

Teleflex completes an assessment of the risk factors relating to modern slavery in relation to the company's supply chain; the factors considered include; the country of supply, the inherent risk of each product, such as the production processes and industry risks, the relationship with the supplier and the volume of purchase.

The risks identified are mitigated by the policies, procedures, and processes implemented, including the use of a supply chain management tool to engage with suppliers own practices.

Our Policies on Slavery and Human Trafficking

Teleflex’s labour standards policy, which can be found at: https://www.teleflex.com/emea/en/suppliers/ethics/ prohibits any kind of forced or child labor. It also states that Teleflex and its suppliers must uphold the human rights of all employees, whether full-time, part-time, temporary, student, contract, or other employment status.

Teleflex and its suppliers will not use any form of forced, bonded, indentured, or prison labour. All work must be voluntary, and employees will be free to leave work or terminate their employment. Employees must not be required to surrender any government-issued identification, passports, or work permits as a condition of employment. Teleflex and its suppliers will ensure that third party labour agencies providing employees are compliant with the provisions of this policy and applicable laws and regulations. Teleflex and its suppliers will ensure that contracts for both direct and contract employees clearly convey the conditions of employment in a language understood by the employee.

The Labour standards Policy is supported by our Code of Ethics Policy.

Supply Chain Risk

The Global Commodity Management and the site purchasing teams work closely with our suppliers to reduce potential pressures within the supply chain.

Teleflex works with an array of suppliers to purchase goods for the demand we see from our customers. Our S&OP process prepares production and supply plans that enables Teleflex to couple the demand from our customers with supply from our suppliers. Our ERP driven purchase order process manages the order transfer to our approved suppliers and our Purchasing and Global Commodity Teams work with these suppliers to maintain lead times, pricing and supply plans.

There are 4 levels of LSAS maturity. Teleflex s currently at Level 3 maturity (Established) and this milestone was achieved in September 2021. The programme analysis of the supply chain for 2022 shows for the 522 suppliers mapped in the supply chain to date, 2 suppliers are classed as critical, 23 are high risk, 95 are medium risk, and the remain 402 are low risk.

Management System

Teleflex is committed to establishing a management system designed to

1. Ensure compliance with this policy and applicable laws and regulations;
2. Identify and mitigate related operational risks; and
3. Facilitate continuous improvement.

The system is driven by the company Quality Management System processes and checked for its effectiveness and continual improvement via the internal auditing programme and management reviews.

Reporting of Issues

Teleflex maintains a third party run ethics whistleblowing reporting system. Any person who knows or suspects violations of this by any employee or third party working for or on behalf of Teleflex shall report it through one or more of the following channels:

• The third party’s Teleflex sales representative or relationship owner;
• The respective Teleflex Regional Compliance Officer (RCO); or Teleflex’s Chief Compliance Officer
• Teleflex’s Vice President Internal Audit
• Teleflex’s General Legal Counsel
• or Through the Ethics Line at www.TeleflexEthicsLine.com..
  • Available 24/7 and 365 days a year. - Concerns can be reported anonymously via the internet or on the phone. - Available in both English and local languages.

Neither Teleflex employees, nor its third-party representatives will be subjected to retaliation for good faith reports of suspected violations. Contact information for the parties listed above is available on the Compliance section of the Teleflex Corporate website found at www.teleflex.com.

System Effectiveness

During the last 12 months, there have been no instances of modern slavery identified within the company or its mapped supply chain.

However, Teleflex has procedures in place so that should any instances be identified, then there is an escalation process defined so that necessary actions, including remediation, can be initiated.

Teleflex achieved its main LSAS objective for 2022, which was to increase the scope of the LSAS programme, and is assessing suppliers from other areas of the business. A key objective for 2023 is to assess the updated list of suppliers based on their country risk and issue different questionnaires, depending on the risk level for the country they are located in.

Training

Training is provided to all Teleflex Manufacturing Site H.R. Leaders and Global Procurement staff on an annual basis. The purpose of this training is to ensure the following

All manufacturing site H.R. Leaders are aware of their responsibilities as follows
1. Remain up to date with all local labour laws, including international labour standards like Modern Slavery and Human Trafficking
2. Remain vigilant to ensure that Teleflex is at all times compliant with all local labour laws and international best practice
3. Take the appropriate steps with regards to reporting and/or remediation should they become aware of any situations where point 2 above is potentially in breach.
• All Procurement and Quality staff, who interact frequently with our suppliers are aware of their responsibilities as follows
  • Understand the practice of modern slavery and human trafficking and other elements of labour Standards
  • Remain vigilant in their dealings with suppliers and immediately escalate issues as appropriate where they observe potential breaches of these standards.
  • The related policies have been communicated to Teleflex employees via email and/or internal posting on the company intranet “Global Knowledge Network” (GKN) and endorsed by Teleflex executive management.

Teleflex has an annual Labour Standards training programme spcifically developed for mitigating labour risks in the supply chain. It is managed by the Labour Standards programme co-ordinator and in excess of 150 members of the Global Procurement, Global Supplier Quality, and Site H.R. leaders participate in the training. Records of attendance are maintained to ensure compliance and review, where necessary.

Monitoring

Teleflex has established a method of documenting and recording compliance with this policy. In addition to this, Teleflex has also established a process to conduct surveys of suppliers in high-risk geographies.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 2022.

Approved

This statement was approved by Teleflex U.K.’s Board of Directors, who review and update it annually.