Statement on Human Trafficking and Slavery
This statement explains the steps Sotera Health Company (“we”, “us”, “our” and “Sotera Health”) has taken to eliminate slavery and human trafficking from our supply chain. Some jurisdictions have implemented legislation that requires certain businesses to provide public statements in this regard. This legislation includes the California Transparency in Supply Chains Act of 2010 and the United Kingdom Modern Slavery Act of 2015.
Business: Sotera Health is a leading global provider of mission-critical sterilization and lab testing and advisory services to the medical device and pharmaceutical industries. With a combined tenure across our businesses of nearly 200 years and our industry-recognized scientific and technological expertise, we help to ensure the safety of millions of patients and healthcare practitioners around the world every year. Across our 63 facilities worldwide, we have nearly 2,900 employees who are dedicated to safety and quality. We are a trusted partner to more than 5,800 customers in over 50 countries.
Our Policies: Sotera Health is committed to ensuring that it conducts business with respect for human rights, in compliance with all applicable laws and fair labor practices. Our commitment to human rights and ensuring the safety and integrity of our supply chain is evidenced by, and further described in, the Sotera Health Global Code of Conduct (“Code of Conduct” or “Code”) and our Supplier Code of Business Ethics and Conduct (“Supplier Code of Ethics”).
We have a zero-tolerance approach to human trafficking and expect the same high standards and commitment from those with whom we do business. We use our Supplier Code of Ethics to inform suppliers of our values and expectations. Our suppliers are required to treat people with dignity and respect, and ensure a safe working environment for all workers, free from any form of harassment, including but not limited to physical, verbal, or psychological threats, or harsh or inhumane treatment. Human trafficking and involuntary labor in any form is strictly prohibited.
Our Supply Chain: Our procurement team takes an end-to-end view of our business, starting with close collaboration with each business unit’s applicable personnel, to efficiently plan, source and deliver a high-quality, reliable supply of the core goods and services necessary for our business. We purchase these goods and services from thousands of suppliers across various industries around the world.
Our supply chain is global and complex, but we view managing the human rights considerations in our supply base as an important undertaking. To this end, we are continuously working to integrate human rights due diligence into our global procurement processes to minimize the risk of human rights violations and protect these rights within our sphere of influence.
Certification and Verification: Our Supplier Code of Ethics reflects the diversity of our supply base and is available in 11 different languages. Our expectation is that all suppliers comply with our Supplier Code of Ethics. During our onboarding process suppliers receive a copy of our Code of Ethics and are required to sign a standalone certification that they understand and agree to comply with its terms. We further incorporate the requirement to comply with our Supplier Code of Ethics into our purchase order terms and conditions and contracts. We may verify the compliance of our suppliers, as well as suppliers’ suppliers and subcontractors with our Supplier Code of Ethics through a supplier self-evaluation, third party verification or documentation, site visit, and/or audit. If a supplier fails to comply with our policies, or if a supplier is found in violation of any applicable law or regulation, including those related to human rights, we may terminate our relationship with that supplier and any associated contracts with us.
Internal Accountability: Our commitment to human rights is described in our Code of Conduct and Supplier Code of Ethics. Violation of our policies is reportable through the Sotera Health Global Ethics Line. Our Global Ethics Line is available to anyone to report a concern about the business conduct of our employees or suppliers, 24-hours a day, 7-days a week, via toll-free phone number, or online, with services available in multiple local languages.
Training: Our annual compliance training program includes mandatory courses on our Code of Conduct, anti-corruption and anti-harassment. An online training system tracks our employees’ completion of annual training and each employee must annually certify that they are in compliance with and not aware of any violations of our Code.