Introduction
Section 54 of the U.K. Modern Slavery Act 2015 provides information regarding organisations’ efforts to address the issue of slavery and human trafficking.
This statement has been prepared on behalf of Bausch & Lomb U.K. Limited (the Company).
This statement constitutes the Company’s 2022 slavery and human trafficking statement which covers the period 1 January 2022 to 31 December 2022 and sets out the steps that we have taken to help ensure that modern slavery is not occurring in our business or in our supply chain.
We believe in the fundamental respect for human rights of all stakeholders and local communities in which the Company conducts business. We are also committed to taking appropriate steps to tackle modern slavery (including slavery, servitude, forced or compulsory labour and human trafficking), and will monitor our labour force and supply chains to identify and rectify any areas of concern in this regard, which may include terminating business relationships with organisations that knowingly engaged in practices that constitute modern slavery. No human rights violations by the organisation or any director, officer, employee or person doing business on our behalf will be tolerated.
We fully support the intent of U.K. Modern Slavery Act 2015 and oppose human trafficking and slavery in all forms. We believe in the fundamental respect for human rights of all stakeholders and local communities in which the Company conducts business. In addition, in most countries where the company 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. We work to the highest professional standards to ensure that we comply with all laws and regulations applicable to the Company. The Company is committed to improving our practices to combat slavery and human trafficking within our own organisation and within our external supply chain. We expect our suppliers to conduct business abiding to all applicable laws, rules and regulations. We are also committed to taking appropriate steps to tackle modern slavery (including slavery, servitude, forced or compulsory labour and human trafficking), and monitor our labour force and supply chains to identify and rectify any areas of concern in this regard, which may include terminating business relationships with organisations that knowingly engaged in practices that constitute modern slavery. No human rights violations by the Company or any director, officer, employee or person doing business on our behalf will be tolerated. All employees have an obligation to conduct business with integrity including respecting human rights.
Organisation's structure
Bausch + Lomb Corporation (NYSE/TSX: BLCO) began trading under the "BLCO" symbol on the New York Stock Exchange and Toronto Stock Exchange. Bausch + Lomb Corporation is the parent company of the Company, and the Company is part of the Bausch + Lomb group of companies (Bausch + Lomb).
Bausch + Lomb is headquartered in Vaughan, Ontario with corporate offices in Bridgewater, New Jersey. 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.
Bausch + Lomb annually published Corporate Social Responsibility (CSR) report. The purpose of the publication was to establish a foundational reporting structure by which we could publicly share our approach and philosophy to CSR. Initially, this report provided anecdotal global highlights of our progress across a collection of CSR programs, initiatives and efforts driven by our major businesses in support of our shared commitment to fulfil our mission responsibly, ethically and in a sustainable manner. As part of this effort, it has become clear that this is about much more than simply “Corporate Social Responsibility.” It is about recognising that Environmental, Social and Governance (ESG) issues and dynamics influence business success and vice versa. Therefore, it is imperative that we approach ESG in a more strategic way that ensures thoughtful management of our company’s interactions with the natural, human and social capital upon which our enduring success depends. In 2021 Bausch+Lomb issued its inaugural ESG report marking the start of our ESG journey and highlights the foundational work we are embarking on to formalise our ESG strategy and path forward. We are proud to continually grow and evolve in pursuit of new and better ways to fulfil our mission of improving people’s lives with our health care products. Operating with integrity, respecting the environment, advancing global health and patient care, improving our communities and supporting employee growth and well-being are at the core of our ESG philosophy and is endorsed and ingrained at the highest level in Bausch+Lomb. It is central to how we want to run our business. Bausch + Lomb views ESG as doing business well by doing good. Bausch + Lomb is dedicated to implementing sustainable business practices and to identifying opportunities to build and enhance our environmental, social and governance initiatives that support all stakeholders, including employees, consumers, eye care professionals and patients. Each year we publish our ESG Reports which sets out our accomplishments in this area.
Corporate Governance Policies
There has been a significant amount of effort and resources that have been dedicated to implementing a comprehensive compliance programme at Bausch + Lomb including checks and balances to prevent and detect violations of law or company policy. Key elements of our Compliance Programme include:
- Establishment of a Corporate Compliance & Ethics Officer.
- A fully functioning Audit and Risk Committee.
- A Code of Conduct that promotes the highest ethical standards and behaviours for business practices, including a dedicated section on Human Rights and Modern Slavery.
- Extensive guidelines and procedures contained in company policies.
- A variety of training and educational activities offered through many mediums.
- Targeted auditing and monitoring of business activities.
- Anonymous reporting along with other communication mechanisms to raise compliance concerns.
- Well publicised disciplinary guidelines.
Bausch + Lomb’s strong system of internal controls enables the management team to comply with corporate policies and applicable laws and regulations. For many years, we have conducted annual corporate governance training to ensure our employees stay informed, up-to-date and in compliance with our Corporate Governance policies including our:
- Code of Conduct;
- Business Ethics Reporting Policy;
- Global Anti-bribery Policy,
copies of which is available for review at https://ir.bausch.com/investors/corporate- governance/governance-documents.
These policies apply to all Bausch + Lomb employees, officers and directors. Certification on an annual basis that they have received, read, and been trained on these policies (biennially) is required. Bausch + Lomb is committed to adhere to the highest standards of ethics and integrity in all our interactions with patients, healthcare providers, customers, fellow colleagues and other key stakeholders. Bausch + Lomb vigorously enforces these policies and will take prompt and appropriate action, up to and including termination of employment or other relationship, of those found to be in violation.
At Bausch +Lomb, we believe in the fundamental respect for human rights of all stakeholders and local communities in which we conducts business. We are also committed to taking appropriate steps to tackle modern slavery (including slavery, servitude, forced or compulsory labor and human trafficking), and will monitor Bausch + Lomb’s labor force and supply chains to identify and rectify any areas of concern in, 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.
We are committed to 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 accordance with our global Code of Conduct, we respect internationally protected human rights and demand fair and respectful treatment of people inside and outside the company. Our standards are based on the following international human rights standards:
- United Nations Universal Declaration of Human Rights;
- International Labor Organization (ILO) Declaration on Fundamental Principles and Rights at Work and its Follow-up
- OECD Guidelines for Multinational Enterprises
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. We will adhere to such applicable local laws and international requirements. In the event of potential conflicts arising between internationally recognised human rights and national legislation in the countries in which we operate, we are committed to the highest ethical standards in compliance with all applicable laws and internal rules and procedures.
Ethics Point
The Business Ethics Reporting Policy is designed to make it easy for reporters to make disclosures, without fear of any detrimental treatment. Bausch + Lomb maintains an independent Ethics Point Hotline that allows its worldwide employees to provide a confidential way to raise concerns of unethical conduct, including those related to supply chain. It consists of toll-free telephone lines that are available anytime - 24 hours a day, seven days a week in over 100 languages, and an online reporting service. It is operated by an external independent firm. Concerns may be raised anonymously.
The scope of the "Ethicspoint" covers all corporate values and principles of our Code of Conduct, in accordance with the applicable legislation in each country. It is therefore possible to submit human rights complaints under the following categories:
- Human Rights
- Health and safety
- Immediate threat to persons or property
- Compensation and benefits
- Discrimination and
- Harassment
- Retaliation
Complaints received by EthicsPoint are handled according to an established process. After submitting a report through the EthicsPoint website, complainants automatically receive an acknowledgment of receipt, as well as a report key and password that allows them to track the status of their complaint at any time.
All cases reported via EthicsPoint and deemed plausible will be investigated. The complainants can be contacted for this purpose if they have agreed to be contacted. Depending on the severity of the case, appropriate action will be taken.
Confidentiality of complaints is guaranteed and the complaints mechanism guarantees effective protection against discrimination or punishment due to the use of EthicsPoint. The complaints procedure also enables the anonymity of the complainants in accordance with the applicable legal provisions.
Labour Standards Assurance System
The Labour Standards Assurance System (LSAS) has been developed by NHS Supply Chain, in conjunction with the Department of Health and industry bodies. LSAS provides an extra level of corporate, social and ethical governance regarding labour standards, marking a major but progressive change in its procurement methodology. In July 2017, the Surgical Business Unit of the Company achieved Level 2 accreditation of LSAS. In 2021 the Company successfully maintained Level 2 accreditation of LSAS.
We have registered with and completed the UK Government Slavery Modern Assessment Tool to improve protections and reduce the risk of exploitation of workers in their supply chains and have obtained “green” status.
The Company’s Labour Standards Assurance System Policy (LSAS Policy) reflects our commitment to acting ethically and with integrity in our business relationships and to implementing and enforcing effective systems and controls to help ensure slavery and human trafficking is not taking place in our supply chains.
Training on LSAS and the LSAS policy forms part of the induction process for all individuals who work for the Company, and annually thereafter. In addition, the LSAS policy is publicly available on the Company’s website. This policy shall also be communicated to key suppliers, contractors and business partners of the Company, specifically those that are connected to the UK Surgical Business. Conducting annual training on LSAS and the LSAS policy with employees helps them take ownership and accountability for doing their part to create a culture of awareness, a high level of understanding of the risks of modern slavery and human trafficking and compliance to help ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business.
Supply Chain
Supplier Evaluation, Qualification, and Verification
Bausch + Lomb uses a risk-based assessment process for evaluating, verifying and selecting direct suppliers. This qualification process may include supplier questionnaires or audits of supplier facilities, which may be completed by Bausch + Lomb or a third party, following which Bausch + Lomb verifies each direct supplier through the completion of a supplier risk assessment. Bausch + Lomb expects all its suppliers to abide by all applicable laws and regulations and maintain the highest ethical standards.
Supplier Agreements and Certification
In its supply agreements, purchase orders and other arrangements with its direct suppliers, Bausch + Lomb includes provisions requiring such direct suppliers to comply with applicable laws and regulations, including as relates to the products or materials being supplied.
Supplier Audits
Bausch + Lomb regularly conducts audits of its suppliers for compliance with applicable law and regulations and good manufacturing standards, as well as the performance of obligations under and the compliance with the terms and conditions of purchase orders and supply agreements. Bausch + Lomb may conduct these audits directly or may utilise a third party.
Supplier Due Diligence
As part of our LSAS initiative to identify and mitigate risk we contacted all key suppliers within the UK Surgical Business supply chain that were categorised as high and medium risk, requesting that they complete the Company’s Modern Slavery Questionnaire. The Questionnaire seeks information regarding the supplier’s business, including the locations of a supplier’s operations, the policies employed by the supplier, information about labour practices, remuneration, health and safety, how they manage the risk of modern slavery or human trafficking in their supply chains, etc.
In addition, Bausch + Lomb’s Third-Party Due Diligence Standard Operating Procedures contains procedures on carrying out checks on suppliers before we deal with them.
Future
The Company is committed to continually demonstrate additional improvements and enhancements to our processes, which includes ongoing training and further development of initiatives to raise awareness amongst its employees. We have maintained our Level 2 accreditation of LSAS with completion of annual LSAS audit and we continue to aim to demonstrate additional improvements and enhancements to our processes. It is our belief that the process and KPI’s that form part of Level 2 accreditation of LSAS will enhance our visibility and ability to identify modern slavery and human trafficking risks.
The Company strives to continuously improve our management systems and our performance in the areas of labour standards, environmental health and safety, and encourages the same from our suppliers. The Company continually reviews its LSAS Policy to help ensure an evolution of our approach to modern slavery and human trafficking risks.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2022. This statement has been approved and ratified by the board of directors of the Company.
United Kingdom (UK)
