Biomet's California Transparency in Supply Chains Act Disclosure
December 31, 2011; Revised December 15, 2012
As of January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) is effective in the State of California. As a result, many companies manufacturing or selling products in California are required to disclose their efforts (if any) to address the issues of human trafficking and slavery, thereby allowing consumers to make better, more informed choices regarding the products they buy and the companies they choose to support.
Biomet, Inc. and its subsidiaries (collectively, "Biomet") strive to achieve and maintain the highest possible standards of corporate integrity and ethical behavior. Biomet expects that its suppliers will conduct their businesses not only in a lawful manner but also in compliance with the same high standards of integrity and ethics. In order to establish guidelines for such standards, Biomet has established a Code of Supplier Conduct. The Code of Supplier Conduct sets forth and highlights important legal, ethical, behavioral and other requirements for parties who wish to be Biomet suppliers. Specifically, the Code of Supplier Conduct states that suppliers must not support, promote or engage in the practice of slavery or human trafficking, and it requires suppliers to comply with the laws regarding slavery and human trafficking of the country of countries in which they are doing business. Biomet suppliers are further expected to take reasonable and necessary steps to help ensure that their sub-contractors and sub-suppliers conduct business in compliance with the Code of Supplier Conduct. Biomet has recently initiated a social responsibility audit program in certain higher risk locations in Asia to evaluate or address the risks of human trafficking and slavery, evaluate compliance with Biomet standards for human trafficking and slavery in supply chains, and require those suppliers to certify that the materials incorporated into their products comply with laws regarding human trafficking and slavery. Biomet currently requires its suppliers to certify by acceptance of the "Biomet Purchase Order Terms and Conditions" that the materials incorporated into the supplier's products comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business. Suppliers are expected to promptly take corrective action to address any deficiencies identified with respect to compliance with Biomet's Code of Supplier Conduct. If a supplier is found to be in violation of the Code of Supplier Conduct, Biomet will take prompt, remedial measures to address the violation. Biomet reserves the right to terminate its relationship with any supplier for failure to comply with this Code of Supplier Conduct. In the Code of Supplier Conduct, Slavery, Human Trafficking and Child Labor are specifically called out as activities for which Biomet has a zero tolerance policy.
Biomet also has an established Code of Business Conduct and Ethics, which applies to all Biomet personnel, including employees and board members (collectively, "Employees"). Biomet expects its business partners and contractors to share the general principles stated in the Code of Business Conduct and Ethics. The Code of Business Conduct requires Biomet Employees to comply with all applicable laws and regulations, including but not limited to those relating to human trafficking and slavery. While Biomet does not provide specific training on human trafficking and slavery, the Code of Business Conduct and Ethics explains that if an Employee needs guidance on a legal or ethical question or has witnessed or has knowledge of an illegal or unethical activity, he or she should consult with or report the matter to his or her supervisor, senior management, Biomet legal counsel, the Compliance Department, the Human Resources Department, the Chief Executive Officer, and/or the Audit Committee of Biomet's Board of Directors, depending on the specific circumstances. All reports of alleged violations will be investigated by Biomet. If the results of an investigation indicate that corrective action is required, the Company will decide the appropriate steps to take, including discipline, dismissal, and possible legal proceedings. If appropriate, the investigation may be turned over to the applicable outside authorities, and outside investigators may assist in the inquiry. Disregard or deliberate ignorance of the law is not tolerated and may lead to disciplinary action.
Biomet takes the issues of slavery and human trafficking very seriously and will continue doing its part by responsibly managing its supply chains in an effort to eradicate human trafficking and slavery.