California Transparency in Supply Chains Act of2010
The Modern Slavery Act 2015 United Kingdom
The Cooper Companies, Inc. Statement1

The California Transparency in Supply Chains Act of 2010 (SB 657) went into effect onJanuary 1, 2012. The Act requires retailers and manufacturers above a certain size to disclose
efforts undertaken to prevent possible slavery and human trafficking in their supply chains.
The disclosure is intended to provide information to consumers, allowing them to makeinformed choices about the products they buy and the companies they support.
The UK Modern Slavery Act 2015 creates offences and imposes a duty on businesses
supplying goods and services in the UK to report each year on the steps they have undertaken
to ensure their operation and supply chains are free of human trafficking and slavery. Other
countries have similar laws and requirements. This disclosure is also intended to outline theactions Cooper is taking to tackle the risks of human trafficking and slavery in our businessand supply chain.
The Cooper Companies, Inc. together with its subsidiaries (collectively “Cooper”) is
committed to supporting human rights globally within our own organization and within its
external supply base. Cooper expects its suppliers to comply with all applicable regulations
and laws. Cooper fully supports the intent of California's and the UK's laws and opposes
human trafficking and slavery in all forms.
Company Structure and Supply Chain
The Cooper Companies, Inc. (“TCC”) is a global medical device company, listed on theNew York Stock Exchange. TCC is headquartered in San Ramon, California USA, withover 12,000 employees worldwide and products sold in over 100 countries. TCC
subsidiaries include CooperVision (CVI) and CooperSurgical (CSI). CVI manufactures
products at Cooper’s own facilities and through external partners and distributes contactlenses and contact lens products; and CSI provides medical devices, pharmaceutical,
testing and procedure-based solutions to the women's healthcare segment.
Our Policies
The following policies are relevant to monitor and reduce the risk of modern slavery
occurring within our business or its supply chains:

1this Statement;
Supplier Code of Conduct;
Cooper’s Ethics and Business Conduct Policy (especially the Ethics, Compliance andPersonal Responsibility and the Violations of the Policy sections of the policy); andThis statement sets out the steps taken by The Cooper Companies and its subsidiaries, including CooperVision Manufacturing Limited,
CooperVision Limited, CooperVision (UK) Holdings Limited, CooperVision Lens Care Limited, Sauflon CL Limited, CooperSurgical
Holdings Limited and Research Instruments Limited.

 Cooper’s other policies and standards referenced in policies above.
(collectively the “Cooper Policies”)
Due Diligence and Risk Assessment
As part of our initiative to identify, assess and mitigate risks:i.
ii.

Cooper uses a risk-based assessment process for evaluating, verifying andselecting direct suppliers.
Cooper expects all of its suppliers to abide by all applicable laws andregulations and maintain the highest ethical standards.

Supplier Agreements, Supplier Code of Conduct
In its supply agreements, contracts, purchase orders and other arrangements (collectivelythe “Supplier Agreements”) with its direct suppliers, Cooper includes provisions
requiring such direct suppliers to comply with applicable laws and regulations, including
as relates to the products or materials being supplied. Furthermore, Supplier Code ofConduct mandates that Suppliers shall not participate in human trafficking; use any
indentured or forced labour, slavery or servitude or purchase materials or services fromcompanies using forced, involuntary or slave labour.
Measuring EffectivenessWe monitor any instances of non-compliance with the provisions in the Supplier
Agreements and the Cooper Policies to measure how effective we have been in ensuringthat slavery and human trafficking is not taking place in any part of our business or supply
chains. We would tailor appropriate remedial action on a case-by-case basis should there
be any instances of non-compliance.
Training and Accountability
Cooper provides compliance training to its employees from time to time and as necessary.
Cooper has adopted and implemented its Ethics and Business Conduct Policy worldwide
across all divisions, subsidiaries and affiliated companies and is to be followed by all
employees. Employees who commit a material violation of the Ethics and BusinessConduct Policy may face disciplinary action, up to and including termination ofemployment. Materiality of a violation shall be determined on a case-by-case basis by theGovernance Committee and shall be based on the Committee's business judgment in its solediscretion. All employees certify on an annual basis that they have received, read, and been
trained on the Ethics and Business Conduct Policy.
Cooper continues to assess and evaluate its supply chain's responsible sourcing practices.
We strive to enforce best practices in our supply chain and within the entirety of ourorganization.