California Transparency in Supply Chains Act Disclosure
Gen-Probe is committed to ensuring that our supply chain reflects Gen-Probe's core values and respect for human rights and the environment. The California Transparency in Supply Chains Act of 2010 (SB 657) (the "Act") was designed to increase the amount of information made available by manufacturers and retailers regarding their efforts (if any) to address the issue of slavery and human trafficking, thereby allowing consumers to make better, more informed choices regarding the products they buy and the companies they choose to support.
The following disclosure is intended to satisfy the disclosure requirements of the Act:
- Verification: We conduct verification of our product supply chain to evaluate and address risks of human trafficking and slavery. At present, this verification is conducted by Gen-Probe employees and is not conducted by third parties.
- Audit: We conduct risk-based assessments of suppliers to evaluate supplier compliance with Gen-Probe standards for human trafficking and slavery in our supply chain, including preliminary risk assessments and supplier assessment questionnaires. These assessments include site visits for approximately ten percent (10%) of our direct suppliers on an annual basis. We use several tools to identify suppliers for on-site audits, including the most recent version of the U.S. Department of State's annual "Trafficking in Persons Report," a list of operational indicators for human trafficking identified by a joint European Commission / International Labor Organization project, and our prior experience with a supplier. At present, these assessments and audits are conducted by Gen-Probe employees and are not conducted by third parties.
- Certification: Starting in December 2011, we adopted a practice of requiring our direct suppliers to certify, on an annual basis, that materials incorporated into the products they supply to us comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.
- Internal Accountability: Employees and management who violate the spirit or letter of Gen-Probe's supply chain policies are subject to disciplinary action up to and including termination of employment.
- Training: We provide company employees and management, who have direct responsibility for supply chain management, with periodic training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chain of products.
Although we believe that it is beneficial for us to work with suppliers to help address and remediate non-compliance with our Supplier Code of Conduct (including our policies with respect to slavery and human trafficking), suppliers that repeatedly fail to meet our Supplier Code of Conduct will be subject to termination.