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Modern Slavery Act Statement

The Modern Slavery Act 2015 (“the Act”) came into effect on 29 October 2015 and requires those entities carrying on a business or part of a business in the UK, supplying goods or services, and having annual turnover of £36 million or more to disclose information regarding the steps they have taken to eradicate slavery and human trafficking from their supply chain as well as within their own organization during the previous financial year.
 
Key Surgical LLC and related parties (“Key Surgical”) publishes this Modern Slavery Act Statement on its corporate website in the name and on behalf of Key Surgical, Clinipak, and Interlock Medizintechnik the fiscal year ended 31 December 2018:
 
UK Modern Slavery Act (“MSA”) Statement
Key Surgical is committed to good corporate citizenship and the highest ethical standards. To fulfil these requirements, Key Surgical has established and maintains systems and controls to ensure that slavery and related human trafficking do not form part of the supply chain.

BUSINESS AND ORGANIZATION
Clinipak was established in 1983, and is a High Wycombe based company and a wholly owned by subsidiary of Key Surgical LLC. Key Surgical is developing a center-led sourcing and procurement organization.
Key Surgical’s organization delivers value by establishing global partnerships and developing relationships with contract manufacturers of consumable medical devices. Key Surgical’s sourcing and procurement organization works with global suppliers across a number of different fields and has business operations in US, Europe and Asia.Key Surgical, Clinipak and Interlock are the leading provider of sterile processing, O.R., and endoscopy products.

VALUES AND TRAININGS
Key Surgical, Interlock and Clinipak are committed to sourcing quality products from suppliers who share its ethical values by aligning the company Code of Conduct with the Ethical Trading Initiative (ETI) Base Code.
 
Key Surigcal’s  Code of Conduct (“Code of Conduct”) provides important guidelines for the company’s interactions with customers, suppliers and other business partners, and one another.
All colleagues are encouraged to raise concerns; this includes violations of (i) the Code of Conduct; (ii) company policies; and (iii) the laws of the countries in which Key Surgical operates. Key Surgical conducts web-based and/or face to face training for employees to emphasize the importance of acting with integrity and in line with the Code of Conduct.

SUPPLY CHAIN AND DUE DILIGENCE
Some of Key Surgical’s suppliers are located in countries that may be more vulnerable to human rights abuses than others. That is why Key Surgical is working to develop several efforts to implement a zero-tolerance policy for such abuses. Key Surgical therefore (i) clearly communicates its expectations to suppliers to ensure adherence of its values and ethical standards; (ii) establishes appropriate policies and processes within its businesses to make sure that the products it is selling meet the highest standards; (iii) utilizes both internal and external resources to evaluate the factories of its suppliers based in higher risk countries and audit them against recognized industry standards; and (iv) requires compliance provisions and agreement within its contracts.

For its sustainable logistics and quality management systems, Key Surgical has designed and implemented a number of processes to assess suppliers of the products introduced into the supply chain. The focus areas included in the assessment process include, but are not limited to, Commercial, Compliance and Quality Assurance. These supplier agreements include language that requires all suppliers to obey national and regional statutory requirements in the country in which they are operating.
If remediation is required, Key Surgical works with its suppliers to improve their standards with corrective action plans and on-going reviews to make sure the standards are maintained. Key Surgical aims to build relationships with its suppliers to ensure adherence to its values and ethical standards.

EFFECTIVENESS
Key Surgical, Interlock and Clinipak carry out periodic supplier audits and, where issues are identified, it works with the supplier to ensure improvements are made. These audits include interviews with workers and the management, inspections of production sites and document reviews. Audit findings or non-conformances are prioritized based on risk. Should a critical issue be identified, Key Surgical would require a timely response from the supplier, and if a supplier failed to adequately remediate the issue, the relationships would be re-evaluated and, if necessary, terminated.
Key Surgical continuously evaluates its monitoring program to ensure all actions are consistent with industry norms, and it believes all efforts to date have been effective in preventing slavery and human trafficking from infecting its supply chain.

This Statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and constitutes Key Surgical’s slavery and human trafficking statement for the previous financial year (FY18).
 
Minnesota, United States
Scot Milchman
CEO
Key Surgical
May 2019
 
GL-REGU-4041, Rev A, 05/2019