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LABOUR STANDARDS ASSURANCE SYSTEM POLICY

 

BAUSCH & LOMB U.K. LIMITED ( the “Company”) is part of the Bausch + Lomb group (Bausch + Lomb), and its ultimate parent company is Bausch + Lomb Corporation , which trades on the New York Stock Exchange and Toronto Stock Exchange, under the ticker BLCO (NYSE/TSX: BLCO). Bausch + Lomb is headquartered in Vaughan, Ontario, Canada with corporate offices in Bridgewater, New Jersey, USA Bausch + Lomb is dedicated to protecting and enhancing the gift of sight for millions of people around the world — from the moment of birth through every phase of life. Its comprehensive portfolio of more than 400 products includes contact lenses, lens care products, eye care products, ophthalmic pharmaceuticals, over-the-counter products and ophthalmic surgical devices and instruments. Founded in 1853, Bausch + Lomb has a significant global research and development, manufacturing and commercial footprint with more than 12,000 employees and a presence in nearly 100 countries

The Company currently delivers ophthalmic products and services to approximately 3,500 customers in the United Kingdom. Our customer base has been essential in enabling Bausch + Lomb to pioneer new technology in this arena and continuously improve our systems in the last ten years. The Company has approximately 4 product and service lines:

  1. Cataract, Vitreoretinal and Refractive Surgery: Our state of the art Phacoemulsification and Vitreoretinal systems are both the building blocks of this service pillar as well as the driving force in technology innovation. We also offer a full suite of products including intraocular lenses and delivery systems featuring the EyeCee One, enVista®, SofPort® and Akreos™ brands of IOLs.
  2. OTC and Optometry Products: Our contact lens offerings span the entire spectrum of wearing modalities and include such well-known brand names as Ultra OneDay®, Biotrue®, PureVision®, SofLens®, Boston® and Optima®. Our lens care products include the ReNu® brand of chemical disinfectants for soft contact lenses as well as the Boston® line of products for cleaning GP contact lenses.
  3. Pharmaceuticals: Our products treat a wide range of eye conditions including glaucoma, eye allergies, conjunctivitis, dry eye and retinal diseases. We offer proprietary and generic medicines available by prescription, over-the-counter eye drops and other medications.
  4. Dermatology Products/Aesthetics Devices: The Company is the distributor of the Solta Medical aesthetics products offering a broad selection of aesthetic medical devices that address a variety of conditions, including skin tightening, skin resurfacing, pigmentation conditions, body sculpting and acne.

The Company currently employs today over 150 staff, fostering a growth mindset and ‘can-do’ attitude at a local level, with the backing and resources made available from the wider Bausch + Lomb group. We take pride in a team that is wholly dedicated to working in strong collaboration with each other and sharing knowledge and skills readily in order to further the unified company success.

Resulting from its business operations, the Company acknowledges its obligations towards its customers, employees and the communities in which it works, and has decided to document its policy in relation to labour standards which is approved by the Company’s Leadership Team,which includes the Surgical Business Unit Director and the General Manager.

The Company’s Leadership Team define this policy as relevant to the organisation itself, its contractors, subcontractors, suppliers and other parties engaged through the supply chain.

Scope of Policy

This policy applies to the Company and its employees.

Nature and Scale

The Company commits to periodically review this policy in order to continually improve, taking into consideration changes in legislation, and any other requirements to which the Company subscribes, and in order to ensure the adequacy, suitability and continuing effectiveness of the policy.

The Company recognises the important part businesses can and should play in tackling slavery and its obligations pursuant to the Modern Slavery Act 2015, the Company monitors UK and global legislation developments, to ensure continued compliance in preventing exploitation and human trafficking and protecting our workforce and identification of any further opportunities to maintain transparency and compliance throughout its supply chain.

Specifically, the policy will be routinely reviewed at the Company’s Leadership Team Meetings.

Minimum Labour Standards

At Bausch + Lomb, we believe in the fundamental respect for human rights of all stakeholders and local communities in which the Company conducts business. This commitment is enshrined in our Code of Conduct , a copy of which is available for review at: https://ir.bausch.com/investors/corporate-governance/governance-documents

Our Code of Conduct provides that Bausch + Lomb is committed to:

  • taking appropriate steps to tackle modern slavery (including slavery, servitude, forced or compulsory labour and human trafficking), and will monitor Bausch + Lomb’s labour force and supply chains to identify and rectify any areas of concern in this regard, which may include terminating business relationships with organizations that knowingly engaged in practices that constitute modern slavery. No human rights violations by Bausch + Lomb or any director, officer, employee or person doing business on our behalf will be tolerated;
  • conducting our business activities in compliance with human rights laws globally and adhering to the basic human rights principles outlined in the United Nations Universal Declaration on Human Rights.

 

In addition, in most countries where Bausch + Lomb conducts business, there are relevant local laws that overlap with our international human rights requirements, including criminal laws and laws regarding child labour, freedom of association, equality of economic opportunity, accessibility and accommodation, and compensation. The Company adheres to such applicable local laws and international requirements.

The Company is committed to transparency in its own business and in its approach to tackling modern slavery throughout its supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.

In addition, the Company has identified the following compelling reasons to establish and maintain a comprehensive system of Minimum Labour Standards to guide it in its business operations.

  1. ETHICAL RESPONSIBILITIES - the Company acknowledges its obligations towards its customers, employees and the communities in which it works arising from its business operations and wishes to work and trade in an ethical manner.
  2. THREAT TO SECURITY OF SUPPLY – the Company has identified that labour standards abuses in supply chains can pose a risk to the security of supply. Any supply chain partners perpetrating abuses face legal enforcement action which may damage business and interfere with their ability to continue to supply.
  3. ADVERSE PUBLICITY AND DAMAGE TO THE COMPANY’S REPUTATION – adverse publicity from the discovery of labour standards abuses in the Company’s supply chain presents reputational and structural risks as follows – (a) income – customers may choose to purchase supplies and services from other providers (b) staff recruitment and retention – staff may choose not to work for a Company associated with any labour standards abuses and this may lead to poor morale in the work place and difficulty in recruitment (c) loss of trust – both with customers and suppliers and also within the wider community.
  4. REDUCED QUALITY OF GOODS AND SERVICES – the Company recognises that there is commonly a link between poor labour standards and poor quality of goods and services. To this end, it is in the interest of the Company to ensure its suppliers reach minimum labour standards targets at all times.

The Company is committed to acting ethically and with integrity in all our business dealings and relationships and that all those under our control comply with applicable laws and ethical obligations. To help it identify a defined set of minimum labour standards, the Company has particularly referred to the following resources:-

  • Social Accountability International’s SA8000 document and the UN’s Universal Declaration of Human Rights;
  • Our Code of Conduct..

 

The Company has identified the following minimum labour standards:

  1. Child Labour – the Company does not engage in or support the use of child labour. If the company engages any young workers (eg: on work experience), it will ensure that a suitable risk assessment is carried out and that young persons are not exposed to any hazardous conditions, or in any case work more than 8 hours per day.
  2. Forced & Compulsory Labour – the Company shall not engage in or support the use of forced or compulsory labour, or bonded or involuntary prison labour. Employees are free to leave upon reasonable notice.
  3. Health & Safety – the Company shall provide a safe and healthy workplace environment and shall take effective steps to prevent potential accidents and injury to employees’ health by minimizing, so far as is reasonably practicable, and in co-operation with its employees, the causes of hazards inherent in the workplace. All employees will receive safety and job specific instructions during the course of their employment with the company. Employees shall have access to clean sanitary facilities and drinking water. Responsibility for implementing the Health & Safety element of this policy is assigned to the General Manager and Leadership Team.
  4. Freedom of Association – the freedom of association is respected and the Company shall comply with UK labour relations legislation in this regard.
  5. Discrimination – the Company shall not engage in or support any discriminatory practices in hiring, remuneration, access to training, promotion, termination or retirement based on race, national or social origin, caste, religion, gender, sexual orientation, political affiliations, age or other conditions that could give rise to discrimination. The Company has an Equal Opportunities and Diversity Policy which is provided to all new employees at induction.
  6. Disciplinary Practices – the Company shall treat all employees with dignity and respect. The Company shall not engage in or tolerate the use of corporal punishment, mental or physical coercion or verbal abuse of personnel. No harsh or inhumane treatment is allowed.
  7. Working Hours – the Company shall comply with applicable laws and industry standards on working hours and holiday entitlements. The Company’s normal working hours do not exceed 48 hours per week, and overtime hours do not exceed 12 hours per week. The Company ensures all employees have the legal right to be employed in the UK.
  8. Remuneration - the Company shall comply with national laws and regulations with regard to wages and benefits. All work related activities are carried out on the basis of a recognised employment relationship established according to national law and practice.

The Company commits that:-

  • its key contractors, sub-contractors and suppliers are made aware of this policy
  • it shall make available sufficient resources for the implementation of this policy.
  • it shall complete an annual assessment utilising the UK Government Modern Slavery Assessment Tool and take appropriate actions based on the subsequent bespoke report.
  • it shall maintain a ‘green’ status as defined by the UK Government Modern Slavery Assessment Tool.
  • it shall comply with relevant legal and other requirements to which it subscribes

 

We make an annual Anti-slavery Statement setting out the steps we have taken to ensure slavery and human trafficking is not taking place in our supply chains and to demonstrate that we take our responsibilities to our employees, people working within our supply chain and our customers seriously. We make this Anti-slavery Statement together with this Policy available on our website.

Training on this policy, forms part of the induction process for all individuals who work for the Company, and annually thereafter. In addition, this policy shall be available internally via HR SharePoint and shall be publicly available on the Company’s website. This policy shall also be communicated to key suppliers, contractors and business partners, specifically those that are connected to the UK Surgical Business.

Jenni White
General Manager,
UK&I June 2023 - Version 7