On January 1, 2012, the state of California enacted the California Transparency in Supply Chains Act (SB 657). This Act requires large retailers and manufacturers doing business in California to disclose on their websites their “efforts to eradicate slavery and human trafficking from their direct supply chain for tangible goods offered for sale.”
At Tandem Diabetes Care, Inc. (“Tandem”), we believe we have a responsibility to source our materials in a legal and ethical manner. As part of the company’s commitment to supply chain transparency, and in compliance with the California Transparency in Supply Chains Act, we make available our efforts to prevent and address slavery and human trafficking in our supply chain. As part of our effort to provide transparency, we conduct the following:
Verification
Tandem engages in verification of its supplier and contract manufacturer supply chain to evaluate and address supplier risks. Preliminary risk assessments are performed by Tandem on potential suppliers with Supplier Qualification Surveys. Upon review of the survey, as determined appropriate, Tandem may follow-up with an in-depth assessment, which may include assessing the risk related to the potential for slavery and human trafficking. Tandem reserves the right to utilize third parties for supplier verifications.
Audit
At the time of supplier selection and qualification, suppliers are required to represent and warrant that they will comply with all appropriate laws, including those that relate to the elimination of human trafficking, child labor and slavery. Once a supplier is approved, a Supplier Scorecard and ongoing Supplier Performance Evaluations are conducted by the Supplier Management Team at scheduled intervals. The evaluations focus on quality management system compliance and quality performance, are conducted by Tandem. Suppliers are required to follow Supplier Corrective Action Requests which outline how the supplier will resolve any issues uncovered in an evaluation. Tandem reserves the right to utilize third parties for supplier evaluations.
Certification
Tandem’s written supply agreements require a supplier to comply with all applicable laws, including those regarding slavery and human trafficking of the country in which the supplier is doing business.
Accountability
Tandem maintains and enforces internal accountability standards and procedures for employees through a Code of Business Conduct and Ethics for Employees and Directors. Suppliers and contract manufacturers are held accountable through contractual agreements which outline standards related to slavery and human trafficking. In the case of non-compliance or suspected non-compliance, Tandem reserves the right to review the specific situation and develop a best possible strategy for resolution. Tandem may terminate a business relationship if any such standards are not upheld.
All Tandem employees are required to comply with Tandem’s Code of Business Conduct and Ethics. All Tandem employees participate in annual training on the company’s Code to ensure understanding and compliance with the requirements of the Code. This training includes ethical decision making and upholding laws and regulations. In addition, Tandem maintains a compliance program that conducts audits of certain requirements under the Code and other compliance policies, investigates potential violations and takes disciplinary action when necessary.