Labor and human rights

While it is the duty of governments to protect the rights of their citizens, Boston Scientific recognizes that businesses also have a critical role to play. As a global medical device company, Boston Scientific respects and strictly adheres to all labor and human rights laws including, among others, those related to modern slavery, child labor, human trafficking, bribery, discrimination, harassment and pay equity. We strive to conduct our business ethically and in a way that demonstrates respect for globally recognized human rights and the dignity of all people, and we require the same of our contractors, suppliers and business partners across the globe.

We require the same standards of our contractors, suppliers and business partners across the globe. By way of example, our Supplier Guidebook mandates adherence to all human rights laws and labor standards, and requires that safe and healthy working conditions be maintained at all times.

The company’s commitment to embracing and advancing human rights is an integral part of our business. We believe that the similarities, the differences and the empowerment of our people allow us to sustain competitive advantages that lead to extraordinary business results. And we are committed to those beliefs because a truly inclusive work environment — one with a richness of backgrounds and perspectives — is one that respects and stands for human rights.

Boston Scientific believes that corporations have a responsibility to respect and protect human rights. Boston Scientific supports the U.N.’s foundational principles of human rights, including the following:

• Boston Scientific respects human rights, seeks to avoid the infringement upon the human rights of all people and seeks to address adverse human rights impacts on all people.
• In order to meet this responsibility, Boston Scientific has established appropriate policies and procedures that help it in fulfilling its responsibility to respect and advance human rights while enabling remediation whenever necessary. We expect the same of our contractors, suppliers and business partners across the globe.

The International Bill of Human Rights consists of the Universal Declaration of Human Rights, the International Covenant on Economic, Social and Cultural Rights, and the International Covenant on Civil and Political Rights and its two Optional Protocols. Some basic tenets are as follows:

• “All human beings are born free and equal in dignity and rights. They are endowed with reason and conscience and should act towards one another in a spirit of brotherhood …”
• “No one shall be held in slavery or servitude; slavery and the slave trade shall be prohibited in all their forms …”
• “Everyone has the right to work, to free choice of employment, to just and favourable conditions of work and to protection against unemployment …”
• “Everyone, without any discrimination, has the right to equal pay for equal work …”
• “Everyone who works has the right to just and favourable remuneration ensuring  for himself and his family an existence worthy of human dignity …”

Boston Scientific fully supports the U.N. International Bill of Human Rights.

Boston Scientific is committed to acting ethically in dealing with customers, employees, shareholders, partners, suppliers, competitors and the community and with respect for applicable laws. One way we make this happen is through the implementation of our Global Compliance Program, explained further here. The primary purpose of this program is to detect and prevent violations of laws, regulations and company policies, taking into account and tailoring the program to our unique environment. Our Code of Conduct is a cornerstone of our compliance program and provides guidance regarding business conduct and practices to all Boston Scientific team members.

Boston Scientific complies with United States and international human rights principles and conventions as explained in the Compliance and Ethics section of the Boston Scientific internet site. When reviewing existing or planned operations, human rights aspects are assessed under these criteria.

Boston Scientific provides a number of resources that employees and others can use to ask a question, obtain guidance or report a Code of Conduct concern. Read more about the Advice Line here.

Boston Scientific is unaware of any human rights violations perpetrated by the company, its employees and its affiliates in the past five years. In the event that Boston Scientific determined such a violation occurred, Boston Scientific would take swift and appropriate action to address the issue, as previously discussed.

Boston Scientific encourages employees to participate in human rights initiatives. Our collaboration with partners including historically Black colleges and universities, the Human Rights Campaign, Disability:IN, the Hispanic Association on Corporate Responsibility and the Society of Women Engineers helps support hiring and development of talent from underrepresented groups. All employees participate in unconscious bias training and Boston Scientific has increased training for leaders to foster an understanding of microaggressions, the history of racism and how to champion diversity, equity and inclusion.

We are proud that our diversity, equity and inclusion efforts have been widely recognized. Learn more about our leadership awards and recognition here.

Learn more about how Boston Scientific fosters an environment of inclusion, equity and opportunity for all here.

At Boston Scientific, our work is guided by core values that define our culture and empower our employees, including Caring, Diversity, Global Collaboration, High Performance, Meaningful Innovation and Winning Spirit. As of December 31, 2022, we had approximately 45,000 employees. We believe the collective talent of our employees and our shared corporate culture and values give us a competitive edge.

Boston Scientific operates in accordance with the United States Department of Labor and International Labour Organization's (ILO) Core Conventions.

Boston Scientific seeks to recruit and employ local labor when it is compatible with company strategy and hiring needs, as well as product quality and regulatory requirements.

Boston Scientific prohibits all forms of child labor as prohibited by the United States Department of Labor, Fair Labor Standards Act (FLSA) and ILO Conventions C138 and C182 (Child Labour). Boston Scientific supports the rights of children to have access to education, health care and protection from criminal behavior. Boston Scientific, in accordance with local labor laws, does not tolerate managers, contractors or outside consultants who are found to be in violation of labor issues and such relationships may be terminated. We expect the same of our contractors, suppliers and business partners across the globe. Boston Scientific provides employees with regulated hours of work, rest periods and time off consistent with ILO Standards, Working Time and the United States Department of Labor, Work Hours. Boston Scientific prohibits all forms of forced labor or exploitative working conditions as prohibited by the United States Department of Labor, FLSA and ILO Conventions 29 and 105.

Boston Scientific supports the right of individuals to earn such a wage as to be able to afford goods or services for quality of life, food, utilities, transport, health care, education, childcare and personal recreation. This living wage may be in excess of the minimum wage rates and requirements by country. Boston Scientific strives to compensate all employees fairly for the skills and activities performed.

This aspect is addressed within the Boston Scientific Global Compliance Program, discussed on our website in the Compliance and Ethics section.

Boston Scientific is committed to following fair employment practices that provide equal opportunities to all employees. We do not discriminate or allow harassment on the basis of race, color, religion, disability, gender, national origin, sexual orientation, gender identity, gender expression, age, genetic information, military status or any other legally protected status. This is further described on the company’s internet page under Compliance and Ethics and in the Code of Conduct.

In the spirit of Articles 17 and 20 of the Universal Declaration of Human Rights, among others, Boston Scientific supports the right of individuals to join or leave groups of their choosing in accordance with their personal and social interests.

Boston Scientific adheres to the United States Department of Labor and ILO Standards conditions and regulations on collective bargaining.

Boston Scientific provides employees access to policies and information related to policies on the company’s intranet site. There is also regular communication and training on the policies and associated relevant changes. Related policies are also discussed on the company’s internet site under Compliance and Ethics and the Code of Conduct. The Code of Conduct is available in multiple languages to ensure global employee access to this information.

Boston Scientific takes a global approach to prioritizing, executing and monitoring efforts to achieve EHS goals to help ensure employee safety and foster a safety-oriented culture in all of our offices and facilities. A commitment to employee health and safety is a prerequisite to our pursuit of patient care. A shared culture of ensuring the safety and health of our employees enables meaningful innovation and business success. As outlined in our Employee Health & Safety Policy, our strong health and safety performance contributes to competitive strength and benefits not only our employees, but also our customers, communities and shareholders.

Boston Scientific is committed to following fair employment practices that provide equal opportunities to all employees. We do not discriminate or allow harassment on the basis of race, color, religion, disability, gender, national origin, sexual orientation, gender identity, gender expression, age, genetic information, military status or any other legally protected status. Boston Scientific also values diversity and believes that a diverse workplace builds a true competitive advantage.

To ask questions or to report a concern about the company’s adherence to human rights laws and labor standards, individuals may use the Boston Scientific Advice Line. The Boston Scientific Advice Line handles calls 24 hours a day, seven days a week in multiple languages and may be accessed toll-free at 888-968-8425.

For the Year Ended December 31, 2023

This statement (the "Statement") of Boston Scientific Corporation for the year ended December 31, 2023 is prepared in accordance with the United Kingdom Modem Slavery Act 2015 (the "Act") and is made on behalf of the group companies listed below which met the reporting criteria of the Act during 2023*. The Act requires us to set forth the steps taken to ensure modem slavery, as such term is defined in the Act, is not taking place in our business or supply chains. Generally, modem slavery is defined as offenses of slavery, servitude and forced or compulsory labour and human trafficking. When used in this Statement, the terms "we," "us," "our," "Boston Scientific," "BSC" and "the Company" mean Boston Scientific Corporation and its divisions and subsidiaries in the UK.

Information on or connected to our website (or the website of any third party) referenced in this Statement is in addition to and not a part of or incorporated by reference into this Statement. Such additional information speaks as of the date thereof and is not intended to be confirmed or updated by reference herein. Boston Scientific disclaims any liability or responsibility for or endorsement of the information on or connected to the website of a third party.

Boston Scientific is dedicated to transforming lives through innovative medical solutions that improve the health of patients around the world. We are a global developer, manufacturer and marketer of medical devices that are used in a broad range of interventional medical specialties.

Our Global Supply Chain team supports more than 20 key locations around the world with our principal manufacturing facilities and distribution centres¹ located in countries where the prevalence of modem slavery is categorised as low/low-medium risk by Global Slavery Index².

Our products are generally sold directly or through distributors and agents to hospitals or physicians, making Boston Scientific the final step in the supply chain prior to these products reaching the end customer. During 2023, our products were offered for sale by five core businesses:

• Endoscopy: Our Endoscopy business develops and manufactures devices to treat a broad range of gastrointestinal and pulmonary conditions with innovative, less invasive technologies.
• Urology: Our Urology business develops and manufactures devices to treat various urological conditions for both male and female anatomies, including kidney stones, benign prostatic hyperplasia, prostate cancer, erectile dysfunction and incontinence.
• Neuromodulation: Our neuromodulation business develops and manufactures devices to treat various neurological movement disorders and manage chronic pain.
• Peripheral Interventions (PI): Our PI business develops and manufactures products to diagnose and treat peripheral arterial and venous diseases, as well as products to diagnose treat and ease various forms of cancer.
• Cardiology:
  • lnterventional Cardiology Therapies (ICTx): Our ICTx business develops and manufactures technologies for diagnosing and treating coronary artery disease and aortic valve conditions.
  • Watchman: Our WATCHMAN FLX™ Left Atrial Appendage Closure (LAAC) Devices are designed to close the left atrial appendage in patients with non-valvular atrial fibrillation who are at risk for ischemic stroke.
  • Cardiac Rhythm Management (CRM): Our CRM business develops and manufactures a variety of implantable devices that monitor the heart and deliver electricity to treat cardiac abnormalities.
  • Electrophysiology (EP): Our EP business develops and manufactures less­ invasive medical technologies used in the diagnosis and treatment of rate and rhythm disorders of the heart, including a broad portfolio of therapeutic and diagnostic catheters and a variety of equipment used in the Electrophysiology lab.

Whilst the Boston Scientific product portfolio is broad in scope, Boston Scientific does not import into the UK any of the top ten high-risk products for modem slavery and human trafficking for use in our final products.³

We are committed to act ethically and with integrity in all our working relationships, inside and outside the company and in compliance with all applicable laws. We support this commitment through our robust global compliance program. People and partners across our brands and supply chain trust our ethics and our track record of responsibility.

The Boston Scientific Global Compliance team provides employee training and resources for conducting business responsibly, treating customers and suppliers fairly and reporting any ethics concerns. The team is led by our chief compliance officer, who reports to the full Board of Directors annually, the Risk Committee quarterly and to the Audit Committee as warranted. Our compliance experts collaborate with teams across the business to monitor the company's compliance with Boston Scientific policies and applicable laws. In 2023, we allocated additional data analytics resources to strengthen the effectiveness of our Global Compliance team.

Every Boston Scientific employee is required to read, understand and follow the Boston Scientific Code of Conduct, the foundation for all of our business practices and relationships. Annual Code of Conduct training is mandatory for all employees and available in 19 languages. We regularly refresh training content based on updates to company policies, processes and compliance-related risks. Our Advice Line allows anyone to confidentially ask a question and/or report a concern related to compliance, ethics and/or integrity at Boston Scientific. It is operated by a third-party vendor and available 24 hours a day, seven days a week in 61 languages. Information about Boston Scientific's Advice Line is communicated to employees as part of on-boarding and reinforced through annual Code of Conduct refresh training and global Integrity Week campaigns plus other compliance campaigns, such as encouraging Managers to have an "Open Door" to ensure employees feel comfortable raising questions and concerns. In 2023, 80% of concerns reported were made directly by an employee to a resource designated in the Code of Conduct (e.g., Compliance, HR, Manager, etc.), highlighting the success of the "Open Door" initiative.

Further, Boston Scientific has a strict non-retaliation policy, whether direct or indirect, against an individual who raises a concern in good faith. This protection extends to anyone who assists with, or cooperates in, an investigation of such a report.

We are committed to conducting business with suppliers who adhere to the highest ethical standards and comply with laws and regulations applicable to their business, including laws related to human trafficking and slavery. We work to advance principles of human rights as recognized and understood by the international community, which include freely chosen employment, avoidance of child labour, reasonable working hours, fair wages and benefits, and humane treatment. Due to the technical complexity of many of our products, our supply chain requires skilled full-time workers, reducing the risk of modem slavery in our business. Despite this we remain vigilant throughout our supply chain to identify and eliminate modem slavery risk. Boston Scientific has developed data analytic capabilities to map third party manufacturers throughout our supply chain to further assess the risk of modem slavery. In 2023, we expanded our use of artificial intelligence to assess risks throughout our value chain.

Prior to engagement of a supplier, we evaluate the supplier through a risk-based assessment, which may include supplier questionnaires and audits of supplier facilities. Our expectations for compliance with ethical and quality standards are communicated to each potential supplier ahead of any engagement. Our Supplier Code of Conduct sets forth Boston Scientific's expectations for its suppliers regarding corporate responsibility in the supply chain and provides information and guidance on how to conduct business with ethics and integrity. Evaluating potential partnerships against our strict criteria takes time, but partnerships with responsible suppliers are a fundamental component of our commitment to human rights and environmentally sustainable practices, as well as to our business continuity and risk mitigation strategies. Potential suppliers are evaluated based on their commitment to responsible business practices, sustainability, and social responsibility, among other areas. This includes a review of the supplier's corporate principles, core values, and code of conduct policies to assess commitment and adherence to responsible business practices, including upholding human rights and vigilance against human trafficking and slavery.

We have strong engagement with our suppliers through supply agreements, quality agreements and/or purchase order terms and conditions. These contracts include agreement to comply with all laws and regulations applicable to the supply of the service or material in all relevant jurisdictions. Our Supplier Quality team is responsible for ensuring that our vendors understand what is required to meet Boston Scientific's quality standards.

We monitor our supplier performance through desktop and on-site audits, while continually monitoring incoming material key performance indicators to confirm compliance with performance and quality standards. Additionally, we have in place a Supplier Resiliency and Risk program which uses internal systems as well as a third-party platform to monitor risk. This system alerts us to supply issues throughout our supply chain based on publicly available information, including those presenting risks related to corporate responsibility.

Boston Scientific provides internal training on supply chain risks to over 850 global sourcing employees who manage these risks and continues to develop its training programme to meet business needs.

As noted above, we maintain an Advice Line whereby employees and third parties, including suppliers, may ask questions, obtain guidance, or report concerns. Employees and business partners are encouraged to raise questions when they need guidance or clarification and to report any concerns or suspected violations of the Code of Conduct, other Company policies, procedures and/or applicable laws.

This Statement has been approved by the Board of Directors of Boston Scientific Corporation on 9 May 2024.

Michael F. Mahoney
Chairman and CEO
Boston Scientific Corporation

*This statement is made on behalf of the following group entities in the UK: Boston Scientific Limited, BTG Limited, and BTG International Limited.

Vance R. Brown
Director of all the above-listed UK entities