Modern Slavery Act Transparency Statement (Fiscal 2022)
This statement has been published in accordance with section 54 of the UK Modern Slavery Act 2015 (the “UK MSA”) and constitutes the modern slavery and human trafficking statement for Haemonetics Limited and Haemonetics S.A. for the fiscal 2022 period (i.e., April 3, 2021 to April 2, 2022).
Haemonetics Limited and Haemonetics S.A. are all subsidiaries of Haemonetics Corporation, a Massachusetts corporation. References to “Haemonetics,” the “Company,” “we,” “us” or “our” refer to Haemonetics Corporation and its subsidiaries as a whole unless otherwise stated.
Haemonetics is committed to high standards in ethical conduct and the prevention of modern slavery and human trafficking in its business and supply chains. Haemonetics will not tolerate or condone such human trafficking or slavery in any part of our global organization and our suppliers are expected to comply with the guidelines set forth in our Global Anti-Human Trafficking Policy that prohibit such activities.
Organization, Business Structure and Supply Chains
Haemonetics is a global healthcare company dedicated to providing a suite of innovative medical products and solutions for customers, to help them improve patient care and reduce the cost of healthcare. Our technology addresses important medical markets: blood and plasma component collection, the surgical suite and hospital transfusion services. We view our operations and manage our business in three principal reporting segments: Plasma, Blood Center and Hospital.
Haemonetics conducted business in over 90 countries and had distributors in approximately 80 of these countries during fiscal 2022. As of April 2, 2022, we employed the full-time equivalent of 2,821 persons globally, with approximately 78% of our employees located in North America and the remaining 22% located across 19 other countries. As of April 2, 2022, our principal manufacturing centers were located in Pennsylvania and California within the U.S., as well as internationally in Mexico and Malaysia, and our products were distributed worldwide from primary distribution centers in the United States, Europe as well as smaller locations globally.
In general, we design our equipment and consumables and use contract manufacturers to build the devices, while the majority of consumables are manufactured by us. Haemonetics has a complex global supply chain that involves integrating key suppliers and our manufacturing capacity into a global movement of components, including plastics and other petroleum-based products used in our disposables, and finished goods.
Haemonetics Corporation is headquartered in Boston, MA (USA) and is publicly listed on the New York Stock Exchange. Contact information for our global offices is available on our website at www.haemonetics.com.
Policies in Relation to Modern Slavery and Human Trafficking
We are committed to upholding the laws and regulations that apply to our products and services around the world and will not tolerate or condone human trafficking or slavery in any part of our global organization. Haemonetics maintains several policies and practices that reinforce this commitment across our organization, including:
1. Code of Conduct – This document outlines Haemonetics’ commitment to conduct business in a manner that respects human rights, including prohibiting any practices (by the Company or any third party) that allow forced labor, child labor or human trafficking. Any person or entity that works on Haemonetics’ behalf is expected to follow our Code of Conduct, including members of our board of directors, executive officers, employees, vendors and other third parties.
2. Global Anti-Human Trafficking Policy – This policy articulates our commitment to a work environment that is free from human trafficking and slavery, including forced labor and unlawful child labor. The policy prohibits Haemonetics employees, contractors, contract manufacturers, subcontractors, suppliers, vendors, distributors, agents and any other third party partners from engaging in slavery or human trafficking activities. These activities include, but are not limited to, engaging in sex trafficking, procuring commercial sex acts (even if this practice is legal in the jurisdiction where it transpires), using force, fraud, or coercion to subject a person to involuntary servitude or obtaining labor from a person by threats of serious harm to that person or another person or engaging in any other practices related to trafficking in persons.
3. Expectations for Suppliers (adopted in fiscal 2022) – This document reaffirms Haemonetics' commitment to an environment that is free from human trafficking and slavery and our expectation that all Haemonetics suppliers comply with the guidelines set forth in Haemonetics’ Code of Conduct and Global Anti-Human Trafficking Policy that prohibit such activities.
4. Reporting Concerns – Our Code of Conduct and Global Anti-Human Trafficking Policy each specify that our employees, vendors and any third parties who work on Haemonetics’ behalf have a responsibility to speak up if they see or suspect a violation of our Code of Conduct, the law, our policies or our ethical standards, including with respect to human trafficking and slavery. These documents outline multiple resources available if such persons have questions or want to report a concern, including Haemonetics' Integrity Helpline that is available 24 hours a day, seven days a week by phone or online. Haemonetics’ Integrity Helpline is managed by an independent third party. Reports can be submitted in most languages and have the option to remain anonymous.
Supplier Adherence to our Values
Haemonetics' Code of Conduct is a manifestation of the values that unite us across our business globally. We expect our suppliers to share our commitment to the same high ethical standards and to follow our Code of Conduct.
In fiscal 2022, Haemonetics published an Expectations for Suppliers statement that reinforces specific expectations for Haemonetics suppliers, including compliance with the guidelines set forth in our Global Anti-Human Trafficking Policy. Haemonetics wants to partner with suppliers who operate in a manner consistent with these expectations and to support our suppliers in understanding and conforming with them. Haemonetics may take steps to assess a supplier’s conformance with these expectations and will consider a supplier’s progress in meeting these expectations in its sourcing decisions.
Due Diligence Processes
For our own operations, including our manufacturing and distribution facilities, Haemonetics maintains compliance and ethics programs that foster a culture of compliance with our Code of Conduct, our policies and the law. Our Chief Compliance Officer, in consultation with our General Counsel, has day-to-day responsibility for administering our Code and reports regularly to the Governance and Compliance Committee of our Board of Directors on the Code and our other compliance and ethics programs, including compliance monitoring, auditing, trainings and investigations. We are also committed to reviewing all reported concerns, conducting proper, fair and thorough investigations tailored to the circumstances, and taking appropriate remedial action in the event of a violation of our Code, our policies or the law. The Company is committed to protecting its employees against retaliation as a result of reporting a potential violation of our Code, our policies or the laws and regulations under which we do business.
Within our supply chain, Haemonetics targets completion of quality audits (either in person or virtually) of approximately one-third of our direct suppliers annually, including with respect to violations of our Code of Conduct. In addition, Haemonetics conducts due diligence on all third party distributors which involves reputational background checks and screenings as well as evaluates the distributor’s efforts to assure that human trafficking and slavery do not exist in its operations and supply chain. Haemonetics recognizes that our highest risk suppliers and distributors for purposes of human trafficking and slavery are likely to be found in countries and industries cited for having the highest prevalence of modern slavery and human trafficking violations.
All employees are required to complete annual online training on our Code of Conduct, which includes a standalone module on human trafficking and slavery. The training module defines modern slavery and human trafficking, identifies potential warning signs and articulates ways employees can help combat modern slavery and human trafficking and report suspected violations in accordance with Haemonetics’ Code of Conduct and Global Anti-Human Trafficking Policy. Additionally, Haemonetics periodically conducts training sessions with our global distributors that address their obligation generally to comply with our Code of Conduct.
In fiscal 2022 we published our Expectations for Suppliers statement and commenced rollout of the statement to our global supply chain, including requiring suppliers to acknowledge the statement when responding to Haemonetics’ request for proposals (RFP).
Measurement and Effectiveness of Steps Taken
Haemonetics remains committed to continually improving our policies and practices related to human trafficking and slavery. This commitment includes periodic reviews of our policies and practices and adoption of relevant key performance indicators (“KPIs”) within our organization.
In fiscal 2022 we maintained key performance indicators under which we would:
1. Target 100% global employee participation in our annual Code of Conduct training, which (as discussed above) includes a dedicated section on modern slavery and human trafficking; and2. Target quality audits of approximately one-third of our direct suppliers annually either in-person or virtually.
We expect to publish our first Corporate Responsibility report in fiscal 2023 that will report further on the above-referenced KPIs and other efforts to improve our policies and practices related to human trafficking and slavery.
This modern slavery and human trafficking statement has been approved by the boards of directors of Haemonetics Limited and Haemonetics S.A. for the fiscal 2022 period ended April 2, 2022.
/s/ James C. D’Arecca
Member of Board of Directors of Haemonetics Limited and
Date: October 27, 2022