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 calendar year 2023. 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 2023 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 labor 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 31, 2023, Insulet had offices in 11 countries, with approximately 3,000 full time employees, and products accessible in 25 countries in North America, Europe, the Middle East, and Asia Pacific. In 2023, Insulet manufactured its products both at its own manufacturing facility in Acton, Massachusetts (United States), as well as through contract manufacturers in China, and its component manufacturing facility in California (United States). Additionally, Insulet is constructing a new manufacturing facility in Malaysia.

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 labor 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 & Privacy 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 expects its suppliers to conduct business with integrity and care for worker well-being. In line with this expectation, 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. Insulet adopted the RBA Code of Conduct as The Insulet Supplier Code of Conduct (“Supplier Code”), which serves as the backbone of Insulet’s supplier responsibility program.

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 an evolving document, updated every three years, that incorporates stakeholder feedback and is available in over 25 languages. The Code was most recently updated in January of 2024.

Human Rights Statement: Insulet adopted its Human Rights Statement in  early 2023. The Human Rights Statement affirms Insulet’s commitment to conducting business in a manner that demonstrates respect for human rights and protecting the dignity of everyone who interacts with an Insulet product, from component sourcing to customers managing their diabetes. The principles outlined in the Human Rights Statement align with 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. Insulet is committed to respecting the rights of vulnerable groups, including those vulnerable to the risks of forced labor and modern-day slavery.  

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.

In 2023, Insulet developed an environmental, social and governance (“ESG”) addendum for inclusion in contracts with all new Malaysia-based suppliers. Among other things, this requires suppliers to implement policies and procedures that mitigate the risk of forced labor. Insulet’s Legal and Procurement Teams are working together to implement the contract addendum with all applicable suppliers.

Governance

The Nominating, Governance, and Risk Committee of the Insulet Board of Directors oversees Insulet’s compliance and ethics program and its Sustainability program.

Insulet’s Vice President of Global Sustainability and Chief Sustainability Officer (“CSO”) leads the sustainability strategy in alignment with the global growth plan and manages Insulet’s ESG practices. The CSO generally meets with the Nominating, Governance, and Risk Committee twice per year and the full Board once per year to report on ESG progress and enhance the Board’s knowledge and awareness of key ESG topics and risks.  

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 & Privacy Officer and Vice President, Internal Audit and Risk Management. 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 2023, the Procurement team hired a dedicated Program Manager to manage 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 annually and when there are key updates to policies and procedures. Insulet’s goal is for 100% of employees to certify compliance. In 2023, 100% of Insulet employees completed training and certified adherence to the Code.

Furthermore, in 2023 Insulet conducted several different training sessions which focused on educating key functions and leaders on the risks of forced labor:

• Malaysia-Based Employees and Leadership Training: In October 2023, Insulet held a 3-day onsite training in Malaysia for key leaders of the Malaysia Management team including the factory General Manager, as well as functional leaders and representatives from the Human Resources, Procurement, Operations, and Facilities teams. This training included a deep dive into the RBA Code, as well as a full day of training specific to the risks of forced labor and tools for risk mitigation.  
• US-Based Employees and Leadership Training: In November 2023, Insulet held an additional onsite training at its Acton headquarters. The training audience included the US based Procurement team and other team members who interact regularly with suppliers from functions such as Supplier Quality and Supplier Engineering, as well as the Operations Leadership team. The training focused on providing an overview of relevant topics such as the International Labor Organization (ILO) indicators of forced labor, common forced labor gaps found in Insulet-specific sourcing regions, and ways to identify, mitigate, and remediate forced labor.  

Suppliers

In addition to the two training sessions described above, Insulet also facilitated and paid for key representatives of three of its new Malaysia-based suppliers to attend a two-day in-person training in Penang, Malaysia led by the RBA. This training provided an overview of the topic of forced labor. It also provided a deep dive into the RBA’s Responsible Labor Recruitment Due Diligence toolkit including several practical case studies to help participants familiarize themselves with the tools for use in their own businesses.  

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 builds out its new manufacturing facility in Malaysia, mitigating the risks of forced labor is top of mind.  

Supply Chain

Insulet aims to partner with suppliers committed to conducting business in accordance with high ethical standards. The Procurement and Sustainability teams are continuing to work closely to incorporate environmental and social factors into supplier selection and management processes in order to identify and mitigate modern slavery risks, among others. For example, in 2023:  

• Insulet requested its top-spend suppliers¹ to confirm that they had read and understood the Supplier Code. In 2022, 96% of top-spend suppliers completed this task, and Insulet engaged with suppliers to reach 100% code acknowledgment for all applicable suppliers by early 2023. Insulet plans to repeat this acknowledgment process in 2024 in order to communicate the latest version of the Code to its supply base.  
• Insulet continued to monitor its supply base for existing RBA Validated Assessment Program (“VAP”) audit reports from its suppliers. In 2023, 22% of in scope high-risk supplier facilities conducted a recent RBA audit. 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 labor 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.
• As Insulet continues to evaluate potential suppliers for its new manufacturing facility in Malaysia, the Sustainability and Procurement teams are engaging with suppliers to support their efforts to prevent and mitigate potential human rights risks, including risks related to forced labor in their recruitment and employment practices.

Distributors  

Insulet has a standardized due diligence process for vetting prospective distributors of its products. 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 focuses on 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 labor, 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.

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. 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 2023, 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.