Issued: 08-09-2022
Document ID: GO-LAB-P001 Rev 05

TELEFLEX LABOUR STANDARDS ASSURANCEPOLICYOVERVIEW

Teleflex is committed to ensuring compliance to recognized standards which have been established byorganizations such as the International Labour Organization (ILO), the U.S. Department of Labor and the
U.K. Modern Slavery Act 2015, among others. Teleflex shall commit to continuous improvement in aneffort 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 thispolicy and related procedure.
Details are spelled out in the following sections:
•
•
•
•
•

LABOUR AND HUMAN RIGHTSHEALTH & SAFETY
THE ENVIRONMENTETHICSMANAGEMENT SYSTEMSSCOPEThis policy applies to all Teleflex facilities. Teleflex shall also strive to ensure that its suppliers adhere to
the minimum standards which are defined within this policy. Regional differences in labour standards
shall be addressed on a case-by-case basis; however, this policy is expected to cover the requirements
for global compliance.
This policy is supported by our Code of Ethics policy and other policies referenced herein.

Issued: 08-09-2022
Document ID: GO-LAB-P001 Rev 05

Contents

TELEFLEX LABOUR STANDARDS ASSURANCE POLICY.......................................................................................................1
1.

POLICY .....................................................................................................................................................................32.

LABOUR & HUMAN RIGHTS ....................................................................................................................................3
2.1.

Modern Slavery Statement .................................................................................................................. 3

2.2.

Anti-Discrimination ........................................................................................................................................4

2.3.

Anti-harassment/Fair Treatment....................................................................................................................4

2.4.

Prevention of Involuntary Labour...................................................................................................................4

2.5.

Prevention of Underage Labour .....................................................................................................................4

2.6.

Working Hours ...............................................................................................................................................5

2.7.

Wages and Benefits ........................................................................................................................................5

2.8.

Freedom of Association ..................................................................................................................................53.

HEALTH & SAFETY ...................................................................................................................................................5

4.

THE ENVIRONMENT ................................................................................................................................................55.

ETHICS .....................................................................................................................................................................5
5.1.

Corruption, Extortion, or Embezzlement ........................................................................................................6

5.2.

Disclosure of Information ...............................................................................................................................6

5.3.

Privacy ............................................................................................................................................................6

5.4.

No Improper Advantage .................................................................................................................................6

5.5.

Fair Business, Advertising, and Competition ..................................................................................................6

5.6.

Whistle-blower Protection and Anonymous Complaints ...............................................................................6

5.7.

Community Engagement ................................................................................................................................6

5.8.

Protection of Intellectual Property .................................................................................................................7

5.9.

Responsible Sourcing of Materials .................................................................................................................7

6.

SUPPLIER DIVERSITY ................................................................................................................................................77.

MANAGEMENT SYSTEMS ........................................................................................................................................7

8.

7.1.

Company Commitment ..................................................................................................................................7

7.2.

Management Accountability and Responsibility ............................................................................................7

7.3.

Training ..........................................................................................................................................................7

7.4.

Legal Requirements ........................................................................................................................................8

7.5.

Audits and Assessments .................................................................................................................................8

7.6.

Corrective Action Process ...............................................................................................................................8

7.7.

Documentation and Records ..........................................................................................................................8

REFERENCES .............................................................................................................................................. 9

Issued: 08-09-2022
Document ID: GO-LAB-P001 Rev 05

1. POLICYThis policy and its accompanying procedure shall be used as Teleflex’s guiding Labour Standards
Assurance document, outlining a series of minimum requirements based on the fifteen (15) actions
identified as part of the NHS Supply Chain Labour Standards Assurance System (LSAS), which requiresthat minimum working conditions in each of Teleflex’s facilities and, to the extent possible, throughout
its supply chain, are safe, that all employees are treated with respect and dignity, and that sourcing andmanufacturing processes are managed in an environmentally and socially responsible fashion.
The most fundamental aspect of these objectives is the need to understand and comply with theapplicable laws, rules, and regulations of the legal federal, state and local jurisdictions in which anorganization operates.
This policy draws upon internationally recognized standards and best practices in order to advance socialand environmental responsibility. Teleflex is committed to developing and implementing those relevant
policies and procedures that will facilitate the execution of this standard. Likewise, Teleflex expects thatits suppliers will also strive to meet or exceed the standards and practices described within thisdocument.
Teleflex references various resources and examples in developing this policy, including the International
Labour Organization Standards (ILO), the Universal Declaration of Human Rights (UDHR), Social
Accountability International (SAI) guidelines, the Ethical Trading Initiative (ETI), the U.K. Modern Slavery
Act 2015 and the U.N. Global Compact. Teleflex is committed to continuing to develop and maintaindetailed standards that serve to clarify the manner in which it operates its business relative to this policy,
along with expectations for compliance among its suppliers and other affected partners.

2. LABOUR & HUMAN RIGHTS
Teleflex and its suppliers must uphold the human rights of all employees, whether full-time, part-time,
temporary, student, contract or other employment status, and treat them with dignity consistent withstandards and practices recognized by the international community.

2.1. Modern Slavery Statement
Pursuant with Section 54(1) Transparency in Supply Chains etc. of the U.K. Modern Slavery Act 2015,
Teleflex shall publish a ‘slavery and human trafficking statement' for each financial year of theorganisation (the “Modern Slavery Statement”). The Modern Slavery Statement will be publicly
available via Teleflex.com. The Modern Slavery Statement shall set out the steps Teleflex has taken
during the previous financial year to ensure that slavery and human trafficking is not taking place within
its own organisation and supply chains.
The Modern Slavery Statement shall contain information relating to:- the organisation and its supply chains;- its policies in relation to slavery and human trafficking;- parts of its business and supply chain where risks of slavery and human trafficking are the highest;- its due diligence process to mitigate risks of slavery and human trafficking taking place in its
business and supply chains;Issued: 08-09-2022
Document ID: GO-LAB-P001 Rev 05-

training and monitoring in relation to slavery and human trafficking; andKey performance indicators / objectives utilized to measure effectiveness.

2.2. Anti-Discrimination
Teleflex and its suppliers will not discriminate against any employee based on family status, civil
status,race, colour, age, gender, sexual orientation, ethnicity, disability, religion, political affiliation,
union membership, national origin, marital status, veteran status, genetic disposition or carrier
status, or anyother legally protected basis, in hiring and employment practices such as applications
for employment, promotions, rewards, access to training, job assignments, wages, benefits,
discipline and termination. Teleflex and its suppliers will not discriminate against pregnant
employees or require a pregnancy test, except where required by applicable laws or regulations ordeemed prudent for protecting individual well-being or overall workplace safety. In addition,
Teleflex and its suppliers will not utilize medical testing of employees or potential employees fordiscriminatory purposes. Teleflex and its suppliers may require certain medical testing where
specified by applicable law or regulation or deemed prudent for protecting individual well-being or
overall workplace safety.

2.3. Anti-harassment/Fair Treatment
Teleflex and its suppliers must be committed to a workplace free of harassment. Teleflex and its
suppliers will not threaten employees with, or subject them to inappropriate behaviour orpractices, including sexual harassment, sexual abuse, corporal punishment, mental coercion,
physical coercion, verbal abuse or unreasonable restrictions on entering or exiting company
provided facilities.

2.4. Prevention of Involuntary Labour
Teleflex and its suppliers will not use any form of forced, bonded, indentured, or prison labour. All
work must be voluntary and employees must be free to leave work or terminate their employment.
Employees must not be required to surrender any government-issued identification, passports, orwork permits as a condition of employment.
Teleflex and its suppliers will ensure that third party labour agencies providing employees arecompliant with the provisions of this policy and applicable laws and regulations and shall also prohibit
the use of worker paid recruitment fees.
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.

2.5. Prevention of Underage Labour
Child labour is strictly prohibited. The minimum age for employment or work will be 16 years of age.
No person between the ages of 16 and 18 will be employed unless such employment is in compliancewith the health, safety and moral provisions of the ILO Minimum Age Convention No. 138, ILO
Recommendation No. 146 – Minimum Age Recommendation, ILO Recommendation No. 190 – Worst
Forms of Child Labour and any other applicable law or regulation within the operating region.

Issued: 08-09-2022
Document ID: GO-LAB-P001 Rev 05

2.6. Working Hours
Work weeks shall not exceed the maximum set by law within the operating region.

2.7. Wages and Benefits
Teleflex and its suppliers must pay all employees at least the minimum wage required by applicablelawsand regulations and provide all legally mandated benefits. In addition to their compensation forregular hours of work, any overtime hours shall be voluntary, and employees shall be compensated,
at a minimum, for overtime hours at the rate required by applicable laws and regulations. Teleflex
and its suppliers will not use deductions from wages as a disciplinary measure. Employees must be
paid in a timely manner, and the basis on which employees are being paid must be clearly conveyed
to employees in a timely manner.

2.8. Freedom of Association
Teleflex and its suppliers must respect the right of employees to associate freely, form and join
employees’ organizations of their own choosing, seek representation, and bargain collectively, as
permitted by and in accordance with applicable laws and regulations. Teleflex and its suppliers will
not specify non-union membership as a condition of employment. Teleflex and its suppliers must
protect against acts of interference with the establishment, function, or administration of employees’organizations in accordance with applicable laws and regulations. All employees must be able toopenlypresent grievances concerning the work environment or management practices without fearof reprisal.

3. HEALTH & SAFETY
Teleflex recognizes that integrating sound health and safety management practices into all aspects ofbusiness is essential in effectively managing risks and minimizing work related incidents while
enhancing the quality of products and improving employee morale and retention. Suppliers must also
be committed to creating safe working conditions and a healthy work environment for all of theiremployees. Comprehensive policies and procedures are included in the Teleflex internal Global
Knowledge Network’s policy section under “Environmental Health and Safety” as well as in theindividual Teleflex facilities. In 2019 Teleflex launched its EH&S Global Manual, which incorporates our
Zero Harm Programme. This programme incorporates all elements of employee Health, Safety andWellness as well as our Environmental programme.

4. THE ENVIRONMENT
Teleflex and its suppliers must recognize environmental responsibility as an integral part of all businesspractices. Teleflex expects its suppliers to actively support objectives and initiatives focused on
reducing the environmental impact associated with product and process design, facility operation, andwaste generation/emission.

5. ETHICS
Teleflex and its suppliers must be committed to the highest standards of ethical conduct when dealing
with employees, suppliers, and customers. Teleflex has adopted a zero-tolerance policy regarding
violations of certain business ethics and will take immediate and appropriate measures to address non-Issued: 08-09-2022
Document ID: GO-LAB-P001 Rev 05

compliance with stated requirements and expectations.
Highlights are included below. Additionally, Teleflex publishes its comprehensive Code of Ethics policies
on Teleflex.com and on its internal Global Knowledge Network (GKN). Click Code of Ethics for Policy andethics reporting/ numbers.

5.1. Corruption, Extortion, or Embezzlement
Corruption, extortion and embezzlement, in any form, are strictly prohibited. Teleflex and its
suppliers will not engage in corruption, extortion or embezzlement in any form. Violations of thisprohibition mayresult in immediate termination as a Teleflex employee or supplier. Teleflex reserves
the right to take legal action in connection with any violation of these prohibitions.

5.2. Disclosure of Information
Teleflex and its suppliers must disclose information regarding business activities, structure,
financial situation, and performance in accordance with applicable laws and regulations andprevailing industrypractices. Falsification of records or intentional misrepresentation of conditions
or practices is unacceptable and will result in appropriate corrective or legal action.

5.3. Privacy
Teleflex and its suppliers must be committed to protecting the reasonable privacy expectation of
personal information within all levels of business including suppliers, customers, consumers andemployees. Teleflex and its suppliers must comply with privacy and information security laws andregulatory requirements wherever personal information is collected, stored, processed, transferredand shared.

5.4. No Improper Advantage
Teleflex and its suppliers must not offer or accept bribes or other means of obtaining undue or
improperadvantage, including personal fees, gifts or favours. Teleflex is sensitive to even the potential
appearanceof improper interactions. Teleflex employees who fail to comply with these requirements
will be promptly disciplined as appropriate, up to and including termination. Suppliers failing tocomply with this guidance may be disqualified from conducting business with Teleflex.

5.5. Fair Business, Advertising, and Competition
Teleflex and its suppliers must uphold fair business standards in advertising, sales and competition.

5.6. Whistle-blower Protection and Anonymous Complaints
Teleflex and its suppliers must ensure the protection of whistle-blower confidentiality and prohibit
retaliation against employees who participate in such programs in good faith or refuse an order thatis inviolation of their respective Codes of Ethics. Teleflex offers an anonymous complaint mechanism
for employees to report actual or perceived accounting or auditing improprieties in accordance withlocal laws and regulations.

5.7. Community Engagement
Teleflex, through our internal “JOIN Act with Purpose” programme, and its suppliers areencouraged to engage the community and stakeholders to help foster social and economicIssued: 08-09-2022
Document ID: GO-LAB-P001 Rev 05

development and to contribute to the sustainability of the communities in which they operate.

5.8. Protection of Intellectual Property
Teleflex is committed to protecting intellectual property rights and safeguarding customer, supplierandcompany internal information. Teleflex utilizes confidentiality agreements when necessary toprotect intellectual property rights of all parties.

5.9. Responsible Sourcing of Materials
Teleflex and its suppliers must take all reasonable measures to assure that conflict minerals are notsupplied nor used in the manufacturing of parts of products. Conflict minerals include, but are notlimited to, tin, tantalum tungsten and gold originating from the Democratic Republic of the Congo
andadjoining countries or other regions where the purchase of specific minerals may benefit groups
that perpetuate the abuse of serious human rights. Teleflex and its suppliers will practice anappropriate level of due diligence to ascertain the origin of conflict minerals. For more information,
visit Teleflex.com (click here).

6. SUPPLIER DIVERSITY
Teleflex has established processes and practices that establish a fair, open and inclusive businessenvironment that ensures a diverse supply chain of capable, qualified business partners. Examples
include a Supplier Diversity statement on the Teleflex.com public website as well as internal policies andwork instructions outlining requirements. For more information, visit Teleflex.com.

7. MANAGEMENT SYSTEMS
Teleflex is committed to maintaining a management system designed to 1) ensure compliance with thispolicy and applicable laws and regulations; 2) identify and mitigate related operational risks; and 3)
facilitate continuous improvement. The management system shall address the following elements:

7.1. Company Commitment
This policy shall be communicated to Teleflex employees via internal posting on the company intranet“Global Knowledge Network” (GKN) (click here) and endorsed by Teleflex Executive Management
through our Management Reviews as part of our Labour Standards Programme.

7.2. Management Accountability and Responsibility
Teleflex Management is committed to supporting this policy. The Vice Presidents of Global
Procurementand Human Resources are jointly responsiblefor ensuring implementation, complianceand periodic review of the policy.

7.3. Training
Training of key staff in Procurement, Human Resources and Quality is executed annually and each
employee must complete a declaration of understanding and attendance. The training covers the
LSAS programme objectives, Modern Slavery and Human Trafficking and summarises the
expectations of each employee relating to Labour Standards.

Issued: 08-09-2022
Document ID: GO-LAB-P001 Rev 05

7.4. Legal Requirements
This policy and related procedures are reviewed, monitored and endorsed by the Teleflex Legalteam, which is responsible for interpreting applicable laws and regulations and the additional
requirementsimposed by this policy.

7.5. Audits and Assessments
Periodic self-evaluations, Corporate Compliance Assessments and / or third-party reviews shallensure suppliers’ compliance to this policy. This includes scheduling supplier audits in order toreview suppliers’ LSAS.

7.6. Corrective Action Process
Teleflex has in place a procedure for timely correction of any deficiencies identified by an internalor external audit, assessment, inspection, investigation or review. This process includes specificremedies if the responsible party does not complete the defined corrective actions in a timely andacceptable manner. A monthly review of open Corrective Actions is in place to support this process.

7.7. Documentation and Records
Teleflex shall establish a method of documenting and recording compliance, Environment, Health,and Safety, supplier and employee data as required by this policy. Teleflex will put in place the systems
and process to ensure that it complies with applicable data protection regulations and legislation.

Policy ApprovalIssued: 08-09-2022
Document ID: GO-LAB-P001 Rev 05

8. REFERENCES
Please refer to the following websites for information pertaining to standards used to create this policy:
Ethical Trading Initiative – https://www.ethicaltrade.org - Website
ILO Code of Practice in Safety & Health https://www.ilo.org/global/topics/safety-and-health-at-work/lang-en/index.htm - Website
ILO International Labour Standards – https://www.ilo.org/global/standards/lang--en/index.htm - Website
ISO 14001 - https://www.iso.org/iso-14001-environmental-management.html - Website
Modern Slavery Act 2015 - https://www.legislation.gov.uk/ukpga/2015/30/contents - Website
OECD Guidelines for Multinational Enterprises - https://www.oecd.org/corporate/mne/ - Website
United Nations Convention Against Corruption - https://www.unodc.org/unodc/en/treaties/CAC/ - Website