Human Rights Due Diligence

Due diligence across our facilities and supply chain

Medtronic understands the importance of a mature due diligence and risk assessment process across our facilities and our supply chain.

Medtronic has an established process for assessing Human Rights risks across internal operations / facilities and our supply chain.

Internal operations

Medtronic conducts annual risk assessments of its internal operations facilities, and triennial assessments of its commercial facilities. Facilities are assessed for numerous Human Rights risks including: child labor, fair treatment, forced labor, freedom of association, health / safety, and remuneration. Medtronic has implemented a four phased lifecycle for assessing its internal operations facilities, including: external research of applicable laws and regulations per facility location, facility audits, implementation of operational risk controls at each facility, and continuous monitoring and improvement.

Please note: 9% of our workforce is represented by trade unions or works councils.

Human rights complaints reporting line

Medtronic has an anonymous Voice Your Concern hotline that supports our Global Human Rights Framework. In the event that a Human Rights complaint is received through this reporting line, the claim is investigated / substantiated through an internal analysis of the facility in question, including a re-evaluation of the overall facility risk score and implementation of additional operational controls (as required). The Voice Your Concern reporting line is available to all Medtronic employees, contract staff, suppliers, and the public. Learn more about the Voice Your Concern hotline.

Due diligence across our supply chain

Medtronic has partnered with a leading supply chain mapping provider to aggregate multiple data streams across our complex supply chain – for the product lifecycle (from raw materials to final destination) – to identify and mitigate supply risks, including:

Mapping our first tier, and sub-tier, suppliers across our supply chain
Developing supplier risk scorecards based on numerous risk factors
Integrating ongoing monitoring with real-time updates from global Human Rights / Forced Labor watchlists
Developing predictive insights and risk analytics across our supplier network

Supplier Sustainability Assessment

Setting strong standards is a good start, but meaningful monitoring and enforcement is necessary for our approach to be effective. Medtronic’s Supplier Sustainability Assessment program monitors suppliers’ compliance and performance against our standards, prioritizing suppliers where Medtronic has the highest spend and those deemed to be highest risk.

Where areas of risk and / or non-compliance are identified, Medtronic issues corrective action requests to all suppliers identified as a medium or high-risk, and they are expected to promptly address high-priority incidents of non-compliance. Medtronic also conducts on-site workplace conditions inspections and audits the business practices of the majority of high-risk suppliers.

Enterprise risk management

Medtronic has a formal Enterprise Risk Management (ERM) function in place – reporting directly to Medtronic’s senior executives and Board Audit Committee. Human Rights is considered to be, and is elevated as,one of our critical risks.

Accordingly, our ongoing Human Rights risk mitigation activities and the results of Medtronic’s Human Rights program are included within Medtronic’s regular ERM reporting.