California Supply Chains Act

Introduction

Insulet Corporation, headquartered in Acton, Massachusetts (incorporated in the United States), is an innovative medical device company dedicated to simplifying life for people with diabetes and other conditions through its Omnipod® (“Omnipod”) product platform. This Statement is made pursuant to modern slavery legislation that applies in the jurisdictions in which Insulet Corporation and its affiliates (collectively “Insulet”) operate, including section 54(1) of the Modern Slavery Act 2015 in the United Kingdom, and constitutes Insulet’s slavery and human trafficking statement for fiscal year 2024. This Statement also includes disclosures required by the California Transparency in Supply Chains Act

This Statement applies to Insulet Corporation and Insulet International Limited, which is the sales and marketing affiliate of Insulet Corporation in the United Kingdom.

The Statement sets out the steps taken by Insulet during its last fiscal year, 2024 to further build out its management systems to prevent, identify and address human rights and modern slavery risks in its operations and supply chains.

Insulet’s Commitment

Insulet is committed to:

• Conducting its activities in a way that promotes ethical values and behaviour, reflects dealing fairly in business, upholds labour rights, supports health and safety in the workplace and doing business in compliance with all applicable laws and regulations.
• Delivering high-quality products to customers while upholding the social and environmental responsibility of its operations and supply chain.
• Making year-over-year progress to improve practices to combat slavery and human trafficking
• Insulet expects its employees, suppliers, distributors, and all other business partners to do the same.

Insulet’s Business, Operations and Supply Chain

As of December 31st, 2024, Insulet has offices in 11 countries, with approximately 3,929¹ full time employees. Insulet’s products are accessible in 25 countries in North America, Europe, the Middle East, and Asia Pacific. Insulet manufactures its products both at its own manufacturing facilities in Acton, Massachusetts (United States) and Johor Bahru (Malaysia), as well as through a contract manufacturer in China. Insulet also has a component manufacturing facility in California (United States).

Steps Taken to Address Modern Slavery Risks

• Insulet has taken the following steps to address risks of modern slavery practices in its operations and supply chains:
• implementing policies and internal governance procedures (see ‘Policies and Governance’ below);
• mandating modern slavery risk-related training (see ‘Training’ below);
• conducting due diligence and risk assessments on third parties (see ‘Due Diligence, Risk Assessment and Management’ below); and,
• facilitating the reporting of modern slavery risk-related concerns (see ‘Reporting and Investigating Concerns’ below).

Policies and Governance

Policies

Code of Business Conduct and Ethics: Insulet’s Global Code of Business Conduct and Ethics (“Code”) outlines minimum standards of conduct for all employees, directors, and officers, including the obligation to represent Insulet values, uphold human rights and comply with all applicable laws including labour and employment laws, applicable industry codes and high ethical standards. The Code is approved by Insulet’s Board of Directors (“Board”). Its implementation is overseen by both Insulet’s SVP, General Counsel and VP, Chief Compliance Officer. The Code represents a single set of values, rules, standards, and principles applicable to employees working for, or on behalf of, Insulet Corporation or any of its subsidiaries, wherever located worldwide.

Supplier Code of Conduct: Insulet is a member of the Responsible Business Alliance (RBA), the world’s largest industry coalition dedicated to improving corporate responsibility in global supply chains. We adopted the RBA Code of Conduct as our Supplier Code of Conduct, and it underpins our supplier management and procurement practices. The RBA Code (and by extension, our Supplier Code of Conduct) is updated every three years to ensure it adheres to international norms and incorporates stakeholder feedback. The Supplier Code guides Insulet’s approach to responsible supply chain management. Insulet expects its suppliers to adhere to the standards set out in the Supplier Code, which covers social, environmental, and business ethics topics, including extensive requirements related to freely chosen employment and protection of vulnerable workers. The Supplier Code references international norms and standards, including the United Nations Universal Declaration of Human Rights, International Labor Organization’s International Labor Standards, Organization for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises, ISO standards, and many more. The Supplier Code is available in over 25 languages and was most recently updated in January of 2024.

Human Rights Statement The Insulet Human Rights Statement outlines key principles that are reinforced in our employment, ethics, and procurement policies, which are designed to respect human rights within our organization and value chain. The Statement aligns with international standards, including the United Nations Universal Declaration of Human Rights, the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work, and The Ten Principles of the United Nations Global Compact. This Statement is available on the Insulet website. Insulet is committed to respecting the rights of vulnerable groups, including those vulnerable to the risks of forced labour and modern-day slavery.

Conflict Minerals Policy

Insulet has adopted a Conflict Minerals Policy that outlines to suppliers and customers our commitment to responsible sourcing of 3TG throughout our supply chain. The Conflict Minerals Policy is publicly available on our website at: https://investor.insulet.com/ESG

Contracts

As part of its contractual arrangements with suppliers and distributors, Insulet seeks to obtain commitment from its counterparties to comply with applicable laws, rules, regulations, codes, ordinances and orders determined by governmental or regulatory bodies in any jurisdiction where services are performed, including but not limited to, those relevant to the protection of workers and/or employees engaged by Insulet’s counterparty in relation to the performance of the services for Insulet.

Insulet has implemented an ESG addendum to the contract template for new Malaysia-based suppliers that requires them to implement policies and procedures that mitigate the risk of forced labour. Our Legal and Procurement teams are implementing the contract addendum with applicable suppliers.

Governance

The Nominating, Governance, and Risk Committee of the Insulet Board of Directors oversees Insulet’s sustainability approach. Insulet’s Sustainability Reporting Steering Committee provides managerial oversight of our sustainability disclosure and adherence to regulatory compliance.

Insulet’s Vice President of Global Sustainability and Chief Sustainability Officer (“CSO”) reports to the full Board annually and to the Nominating, Governance, and Risk Committee at least twice a year to share our ESG progress and enhance the Board’s knowledge of sustainability strategies and practices.

The Nominating, Governance, and Risk Committee also monitors Insulet’s risk assessment and management process. The Board also receives regular updates on key enterprise risks and opportunities from Insulet’s Vice President, Chief Compliance Officer, Internal Audit and ERM team. The Board routinely meets with other members of management responsible for risk in their respective business functions.

To integrate sustainability throughout its operations, Insulet’s Global Sustainability Team collaborates internally with other functions. This includes close collaboration with the Procurement, Human Resources, Manufacturing Operations, Legal, Compliance, and other relevant functions to build out practices to identify and address modern slavery risks. During 2024, the Procurement team expanded the team by hiring a second dedicated Program Manager to lead its Supplier Responsibility Program.

Training

Employees

All employees and Board members are required to undergo ethics training and to certify adherence to the Insulet Code of Business Conduct and Ethics.

Insulet regularly conducts training focused on educating key functions and leaders on the Supplier Code, including the risks of forced labour.

Suppliers

In addition to the training sessions described above, Insulet also encourages suppliers to attend local RBA training sessions on relevant topics for their specific geographies. In 2024, one supplier in Mexico attended RBA training to learn about best practices and a deep dive into the code of conduct.

Due Diligence, Risk Assessment and Management

Insulet has various due diligence, risk assessment and risk management procedures in place in both its owned operations, and supply chains, and regularly reviews and improves these procedures.

Owned Operations

As Insulet continues to ramp up manufacturing in Malaysia, mitigating the risks of forced labour is top of mind.

Supply Chain

Insulet sources components, materials, commodities and services through a broad supplier network. Insulet’s supply chains include both direct and indirect suppliers who provide a range of products and services. We partner with distributors in the countries where our products are commercially available to our customers.

Insulet regularly makes suppliers aware of our Code of Conduct and adherence to it through various activities including questionnaires, contract language, audits, and recommended training. Insulet also monitors newly evolving regulations in countries we operate and works with suppliers and internal teams to ensure we meet those requirements.

We follow a risk-based approach using country level risk as one indicator to conduct assessments that include onsite observations, worker interviews, and document review. We focus on a continuous improvement approach that allows our suppliers to focus on remediation and to integrate the code of conduct into their operations for long-term impact.

Insulet aims to partner with suppliers committed to conducting business in accordance with its Supplier Code. The Procurement and Sustainability teams are continuing to work closely to incorporate environmental and social factors into supplier selection and management processes to identify and mitigate modern slavery risks, among others

For example, in 2024:

• Insulet requested its top-spend suppliers² to confirm that they had read and understood the updated Supplier Code. For 2024, 100%% of top-spend suppliers completed this task. Insulet will integrate this acknowledgment process into its annual attestation process in 2025 to communicate the latest version of the Code to its supply base.
• Insulet continued to expand audit coverage via the RBA Validated Assessment Program (“VAP”). In 2024, We received and reviewed RBA VAP audit reports for 33%³ of the supplier facilities that we identified as in-scope and high-risk. The RBA VAP sets standards for onsite environmental and social compliance criteria and facilitates shareable audits conducted by independent firms. Audits are typically announced and include procedures to evaluate the risk of forced labour under the RBA Code. The Procurement team reviewed all RBA VAP audit reports and is working closely with relevant suppliers to ensure they address any identified issues and focus on continuous improvement
• As Insulet continues to evaluate potential suppliers for its new manufacturing facility in Malaysia, the Sustainability and Procurement teams are actively engaging with suppliers to support their efforts to prevent and mitigate potential human rights risks, including risks related to forced labour in their recruitment and employment practices and where necessary Insulet will pursue remediation.

Distributors

Insulet has a standardized due diligence process for vetting prospective distributors of its products. The due diligence process serves to better inform Insulet about who the Distributor is and what risks that Distributor may create for Insulet. Insulet’s due diligence process is risk-based, meaning that distributors exposing Insulet to a greater potential risk, receive greater scrutiny. In addition to broad ethics and compliance screening, the due diligence also focuses on exposing ESG risks. At a minimum, all distributors must certify that:

• They have never been accused, investigated, fined, convicted, or received any administrative complaints from any government agency related to misconduct involving human rights, modern day slavery, underaged/forced labour, workplace safety/health or similar practices; and,
• They have never been challenged or faced criticism by NGOs or media in general in relation to human rights or modern-day slavery concerns.

Distributors ranked as medium or high-risk, will undergo enhanced due diligence. This involves commissioning intelligence research – done using media searches as well as a summary of NGO actions from a dedicated ESG data source – focused on exposing integrity risks, including unethical employment practices and modern slavery issues.

Distributors classified as medium or high-risk are subject to additional requirements to repeat the due diligence process. Distributors that are classified as medium risk must undergo Insulet’s due diligence process every three (3) years from the date of completion of the last due diligence. High-risk Distributors will repeat Insulet’s due diligence process every two (2) years.

Reporting and Investigating Concerns

Insulet aims to maintain an environment where individuals have a way to voice their concerns about possible breaches of Insulet’s Code of Business Conduct and Ethics and other Insulet policies, as well as suspected violations of country laws and regulations. Insulet has a dedicated programme ‘Speak Up’ accessible via the company intranet page.

Through its Compliance and Ethics Hotline and Online Portal, Insulet encourages employees, customers, and other interested persons to report ethical concerns. Insulet expressly forbids retaliation against anyone who, acting in good faith, reports suspected misconduct. Insulet is committed to promptly investigating all reports of illegal, unethical, or inappropriate activity. Investigations and remediations are managed by a cross-functional team, with membership depending on the exact nature of the allegation of misconduct.

In 2024, Insulet rolled out a revamped version of its public-facing Compliance and Ethics Hotline and Online Portal, expanding its access from new jurisdictions and making it easier to report on a broader range issue types, including failures on Insulet’s side to provide a safe working environment.

In 2024, Insulet received no reports suggestive of modern slavery.

This statement has been prepared in consultation with key teams at Insulet. This includes the Sustainability, Procurement, Legal, and Compliance teams.

This Statement was approved by the Board of Insulet International Limited on May 22nd, 2025.