Modern Slavery Statement
Glaukos Corporation (“us,” “we” or the “Company”) is a medical technology and pharmaceutical company focused on developing and leading the global ophthalmic market with novel therapies that advance the existing standard of care, and enrich the lives and treatment alternatives for patients.
Policies
We are committed to conducting our business with integrity and the highest respect for human rights. That commitment begins with our Code of Business Conduct and Ethics (“Code of Conduct”), available on our website here. The Code of Conduct applies to all of our officers, employees and directors. The Code of Conduct emphasizes the importance of abiding by the law, being truthful, being fair in our business dealings, and avoiding conflicts of interest and ethical lapses. In addition, we have adopted a Supplier Code of Conduct and Conflict Minerals Policy (“Supplier Code”), available on our website here. The Supplier Code applies to all direct suppliers that provide components to Glaukos for use in Glaukos’ commercial products, and outlines the requirements and expectations for suppliers throughout their operations and entire product supply chain. The Supplier Code requires our suppliersto, among other things:
- Not use child labor
- Comply with all local labor laws, including with respect to wages
- Prohibit all forms of forced or involuntary labor, slavery or human trafficking
- Not engage in discrimination, harassment or abuse
- Provide a safe and sanitary working environment
- Allow us to audit their operations to confirm compliance
- Cooperate with us regarding concerns around conflict minerals
We do not enter into business with any organization which we know supports or is involved in slavery, servitude and forced or compulsory labor. Currently, the majority of our vendors who manufacture or supply parts for our products are based in the United States, Japan or in the EU. While this may result in slightly higher manufacturing costs, we believe it reduces our risk of engaging with irresponsible or unethical supply partners. In our contracts and purchase orders with our suppliers, we require them tocomply with all applicable laws, which includes laws regarding fair labor standards. In 2022, we also began requiring our suppliers to comply with our Supplier Code. We have also adopted a Human and Workforce Rights Policy (”Human RightsPolicy), available on our website here. Our Human Rights Policy reiterates our commitment to upholding human and workplace rights throughout our operations and our products and services, including consistent treatment among people, employee well-being and security, and economic and social freedom provide a workplace free from harassment that provides equal opportunity to all without regard to race, color, creed, gender, religion, national origin or ancestry, or any other consideration madeunlawful by national, state, or local laws. Our Human Rights Policy documents that we will not tolerate human rights abuses, human trafficking and/or slavery and will notengage or be complicit in any activity that solicits or encourages human rights abuse. We promote diversity, equity and inclusion in our workforce by conducting targeted recruitment of minority, women, veteran, and disabled job-seekers and performing annual internal pay equity analyses. We expect our suppliers to develop and implementinternal business processes in compliance with our Human Rights Policy.
Practices
Our contracts with suppliers generally enable us to audit suppliers’ operations and facilities to determine compliance with the Supplier Code. If any supplier cannot demonstrate compliance, we consider taking remedial action, which may include terminating our agreement. Additionally, as stated in our Conflict Minerals Report, weperformed the due diligence necessary to determine which of the designated minerals used in our commercial materials and components are derived from smelters who either not source minerals in the Democratic Republic of the Congo and neighboring countriesor are not conformant to the Responsible Minerals Assurance Process. We also published our Transparency in Supply Chain disclosure required by the California Transparency in Supply Chains Act of 2010 (SB 657), found here.In 2020, we conducted our first annual human rights questionnaire. We requested that certain key glaucoma component suppliers provide information on their labor practices,or comparable information, to fight human trafficking in our supply chain. In 2021, we updated our supplier screening questionnaire for glaucoma key suppliers to includeESG criteria, including establishment of policies on ethics, healthy and safe workplaces, human rights, and conflict minerals, and in 2022, we began requiring our suppliers toagree in their contracts to comply with our Supplier Code.
Training
We understand that a key component of an effective compliance environment isemployee training and education regarding the rules and policies that apply to theirbusiness activities, as well as our commitment to ethical business conduct. Employeesreceive training on the Code of Conduct when they join the Company, as well asongoing training on policies and procedures to reinforce the Company’s commitment tocompliance with laws and ethical behavior. Additionally, our applicable operationspersonnel are periodically trained on how to identify and prevent human traffickingwithin our supply chain.
Reporting
Employees are expected to report any misconduct or unethical behavior to theirsupervisor or our compliance personnel. In addition, our suppliers and their workershave the right to report suspected violations of our Supplier Code or applicable law. TheCompany provides means of reporting concerns of suspected violations of our policiesor applicable law anonymously through a reporting hotline and website that is monitored24-7. These various means of reporting are listed in the Code of Conduct and SupplierCode, and on our website here, and are publicized to employees on a regular basis. Weexpect anyone to report in good faith issues about potential ethical, legal, regulatory, orhuman rights violations. We will employ a prompt and victim-centered response to suchreports. Investigations into reports of known or suspected violations will maintain theconfidentiality of the reporter or victims to the extent possible. Glaukos will make everyeffort to ensure that potential victims are supported and protected to the extent feasibleand receive appropriate recompense. The Company will take appropriate remedialactions to any proven allegations, and reserves the right to terminate the employment ofemployees, or agreements with any supplier, that engages in modern slavery orotherwise violates our Code of Conduct, Supplier Code or applicable law.
This statement has been made and adopted by Glaukos UK Limited pursuant to Section54 of the Modern Slavery Act of 2015 (the “Act”). Although Glaukos UK does not meetthe criteria set forth in the Act requiring it to adopt a Transparency Statement, we haveadopted and approved this statement. This statement covers Glaukos UK’s businessactivities for the fiscal year ending December 31, 2022.
Thomas W. Burns
Director
Glaukos UK Limited
Niven Smith
Director
Glaukos UK Limited