California Supply Chains Act

Introduction

Insulet Corporation, headquartered in Acton, Massachusetts (incorporated in the United States), is an innovative medical device company dedicated to simplifying life for people with diabetes and other conditions through its Omnipod® (“Omnipod”) product platform. This Statement is made pursuant to modern slavery legislation that applies in the jurisdictions in which Insulet Corporation and its affiliates (collectively “Insulet”) operate, including section 54(1) of the Modern Slavery Act 2015 in the United Kingdom, and constitutes Insulet’s slavery and human trafficking statement for calendar year 2022. This Statement also includes disclosures required by the California Transparency in Supply Chains Act.

This Statement applies to Insulet Corporation and the following affiliates:

• Insulet International Limited, which is the sales and marketing affiliate of Insulet Corporation in the United Kingdom.

The Statement sets out the steps taken by Insulet during 2022 to further build out its management systems to prevent, identify and address human rights and modern slavery risks in its operations and supply chains.

Insulet’s Commitment

Insulet is committed to:

• Conducting its activities in a way that promotes ethical values and behaviour, reflects dealing fairly in business, upholds labour rights, supports health and safety in the workplace and doing business in compliance with all applicable laws and regulations.
• Delivering high-quality products to customers while upholding the social and environmental responsibility of its operations and supply chain.
• Making year-over-year progress to improve practices to combat slavery and human trafficking.

Insulet expects its employees, suppliers, distributors, and all other business partners to do the same.

Insulet’s Business, Operations and Supply Chain

As of December 31st, 2022, Insulet has offices in 9 countries, with approximately 2,600 full-time employees. Insulet’s products are accessible in 24 countries in North America, Europe, the Middle East, and Asia Pacific. Insulet manufactures its products both at its own manufacturing facility in Acton, Massachusetts (United States), as well as through contract manufacturers in China. In 2022, Insulet acquired assets from Dynalloy, Inc. related to the design and manufacturing of wire assemblies which drive the pump within Omnipod. This new Insulet facility is based in Irvine, California (United States). Finally, Insulet is currently constructing an additional manufacturing facility in Johor Bahru, Malaysia.

Steps Taken to Address Modern Slavery risks

Insulet has taken the following steps to address risks of modern slavery practices in its operations and supply chains:

• implementing policies and internal governance procedures (see ‘Policies and Governance’ below);
• conducting due diligence and risk assessments (see ‘Due Diligence, Risk Assessment and Management’ below);
• mandating modern slavery risk-related training (see ‘Communications and Training’ below); and
• facilitating the reporting of modern slavery risk-related concerns (see ‘Reporting and Investigating Concerns’ below).

Policies and Governance

Policies

Code of Business Conduct and Ethics: Insulet’s Global Code of Business Conduct and Ethics (“Code”) outlines minimum standards of conduct for all employees, directors, and officers, including the obligation to represent Insulet values, uphold human rights and comply with all applicable laws including labour and employment laws, applicable industry codes and high ethical standards. The Code is approved by Insulet’s Board of Directors (“Board”) (and overseen by Insulet’s General Counsel and VP, Chief Compliance & Privacy Officer). In 2022, the Code was revised and streamlined to create a single set of values, rules, standards, and principles applicable to employees working for, or on behalf of, Insulet Corporation or any of its subsidiaries, wherever located worldwide.

Supplier Code of Conduct: Insulet expects its suppliers to conduct business with integrity and care for worker well-being. In line with this expectation, Insulet is a member of the Responsible Business Alliance (RBA), the world’s largest industry coalition dedicated to improving corporate responsibility in global supply chains. Insulet adopted the RBA Code of Conduct as The Insulet Supplier Code of Conduct (“Supplier Code”), which serves as the backbone of Insulet’s supplier responsibility program.

The Supplier Code guides Insulet’s approach to responsible supply chain management. Insulet expects its suppliers to adhere to the standards set out in the Supplier Code, which covers social, environmental, and business ethics topics, including extensive requirements related to freely chosen employment and protection of vulnerable workers. The Supplier Code references international norms and standards, including the United Nations Universal Declaration of Human Rights, International Labour Organization’s International Labour Standards, Organization for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises, ISO standards, and many more. The Supplier Code is an evolving document, updated every three years, that incorporates stakeholder feedback and is available in over 25 languages.

Human Rights Statement: Insulet adopted its Human Rights Statement in early 2023. The Human Rights Statement affirms Insulet’s commitment to conducting business in a manner that demonstrates respect for human rights and protecting the dignity of everyone who interacts with an Insulet product, from component sourcing to customers managing their diabetes. The principles outlined in the Human Rights Statement align with the United Nations Universal Declaration of Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work, and the Ten Principles of the United Nations Global Compact. Insulet is committed to respecting the rights of vulnerable groups, including those vulnerable to the risks of forced labour and modern-day slavery.

Governance

Insulet Corporation’s Board’s Nominating, Governance, and Risk Committee oversees Insulet’s compliance and ethics program, and its sustainability approach and management of material topics as well.

Insulet’s Vice President of Global Sustainability and Chief Sustainability Officer (“CSO”) leads the sustainability strategy in alignment with the global growth plan and manages Insulet’s environmental, social and governance (“ESG”) practices. The CSO meets with the Nominating, Governance, and Risk Committee generally twice per year to report on ESG progress and enhance the Board’s knowledge and awareness of key ESG topics and risks.

The Nominating, Governance, and Risk Committee also monitors Insulet’s risk assessment and management process. The Board also receives regular updates on key enterprise risks and opportunities from Insulet’s Vice President, Chief Compliance & Privacy Officer. The Board routinely meets with other members of management responsible for risk in their respective business functions.

To integrate sustainability throughout its operations, Insulet’s Global Sustainability Function collaborates internally with other functions. This includes close collaboration with the Procurement, Human Resources, Manufacturing Operations, Legal, Compliance, and other relevant functions to build out practices to identify and address modern slavery risks.

Due Diligence, Risk Assessment and Management

Insulet has various due diligence, risk assessment, and risk management procedures in place in both its owned operations, and supply chains, and regularly reviews these procedures.

As Insulet builds out its team at the new manufacturing facility in Malaysia, the Sustainability and HR teams are working closely to mitigate modern slavery risks in hiring for specific roles. For example, in 2022 Insulet included several desired competencies in the job description of the HR lead around familiarity with international labour standards, and experience developing policies and procedures for responsible recruitment and employment of domestic and foreign migrant workers.

Supply Chain

Insulet aims to partner with suppliers that are committed to conducting business in accordance with high ethical standards. As part of its contractual arrangements with suppliers and distributors, Insulet seeks to obtain commitment from its counterparties to comply with applicable laws, rules, regulations, codes, ordinances and orders determined by governmental or regulatory bodies in any jurisdiction where services are performed, including but not limited to, those relevant to the protection of workers and/or employees engaged by Insulet’s counterparty in relation to the performance of the services for Insulet.

Furthermore, the Procurement and Sustainability teams are continuously reviewing opportunities to further incorporate environmental and social factors into supplier selection and management processes in order to identify and mitigate modern slavery risks, among others. For example, in 2022:

Insulet conducted its first social and environmental supplier base risk assessment using risk data provided by the RBA, including risk indicators pertaining to modern slavery. This data was used to prioritize Insulet requests for existing RBA Validated Assessment Program (“VAP”) audit reports from its suppliers. The RBA VAP sets standards for onsite environmental and social compliance criteria and facilitates shareable audits conducted by independent firms. Audits are typically announced and include a review of whether any type of slavery and/or trafficking is permitted. All RBA VAP audit reports that Insulet received were reviewed by the Sustainability and Procurement teams, who are working closely with relevant suppliers to address any identified issues.

As Insulet evaluates potential suppliers for its new manufacturing facility in Malaysia, the Sustainability and Procurement teams are collaborating to engage suppliers taking account of how they prevent and mitigate potential human rights risks, including risks related to forced labor in their recruitment and employment practices.

Communications and Training

Employees

All employees and Board members are required to undergo ethics training and to certify adherence to the Insulet Code of Business Conduct and Ethics annually and when there are key updates to our policies and procedures. Our goal is for 100% of employees to certify compliance. In 2022, 100% of employees in North America completed training and certified adherence, and we continue to advance tracking processes for additional locations. Our ethics training is reinforced each year during our Quality and Compliance Week, where we host lectures, workshops, and community-building activities related to ethical issues in quality and compliance.

In 2022, Insulet required all employees who regularly interact with suppliers to complete training on the RBA Code of Conduct. This training, which outlined our expectations of suppliers regarding forced labour, was in the format of an e-learning and contained 5 modules which provided an interactive overview of each section of the RBA Code of Conduct. The training was required for employees from various functions, including Procurement, Supplier Quality, and Supplier Engineering, and a 100% completion rate was achieved.

Suppliers

Insulet requests its top-spend suppliers¹ to confirm that they have read and understand the Supplier Code. In 2022, Insulet increased the scope of this top-spend definition to reach a wider supplier base. In 2022, 96% of top-spend suppliers completed this task, and Insulet engaged with suppliers to reach 100% code acknowledgment for all applicable suppliers by early 2023.

Insulet also requested top-spend suppliers to conduct the same RBA Code of Conduct training required of its employees, achieving the same completion rate as the Supplier Code acknowledgement exercise described above.

Reporting and Investigating Concern

Insulet aims to maintain an environment where individuals feel free to voice their concerns about possible breaches of Insulet’s Code of Business Conduct and Ethics and other Insulet policies, as well as suspected violations of country laws and regulations. Through its Compliance and Ethics Hotline and Online Portal, Insulet encourages employees, customers, and other interested persons to report ethical concerns, including but not limited to, directly to the General Counsel or the Chief Compliance & Privacy Officer. Insulet expressly forbids retaliation against anyone who, acting in good faith, reports suspected misconduct. Insulet is committed to promptly investigating all reports of illegal, unethical, or inappropriate activity. Investigations and remediations are managed by a cross-functional team, with membership depending on the exact nature of the allegation of misconduct. In 2022, Insulet received no reports suggestive of modern slavery.

This statement has been prepared in consultation with key teams at Insulet. This includes the Sustainability, Procurement, Legal, and Compliance teams.

¹Defined as the top 90% (increased from 80% in 2021) of Pod bill of materials, value-added manufacturing, and PDM supplier spend.