Supply Chain Transparency and Ethics

Purpose
Stryker Corporation and its affiliated companies ("Stryker") support of responsible sourcing.

Scope
Stryker’s ongoing effort to eliminate the use of Tin, Tantalum, Tungsten and Gold (“3TG”) from sources that may finance armed conflict and promote human rights abuses in The Democratic Republic of the Congo and adjoining countries including: Angola; Burundi; Central African Republic; The Republic of the Congo; Rwanda; South Sudan; Tanzania; Uganda; and Zambia (“Conflict Region”).

Details
Stryker supports responsible sourcing from the Conflict Region and expects its suppliers to procure material containing 3TG from socially responsible sources. The goal is to eliminate funding to human rights abusers while continuing to support socially responsible commerce in the Conflict Region.

In support of this Policy, Stryker will among other things:

• Conduct reasonable country of origin enquiries and exercise ongoing due diligence of its suppliers consistent with the OECD
  Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas to determine whether 3TG from the Conflict Region exist in Stryker’s raw materials, components and/or finished devices, and if so, whether the 3TG was responsibly sourced;
• Require suppliers to conduct due diligence and to provide appropriate information to support the determination of the origin
  of the 3TG used in the products that they supply to Stryker;
• Engage and collaborate with suppliers to work towards sustainably responsible 3TG sourcing; and 
• File an annual Form SD and Conflict Minerals Disclosure and Report with the US Securities and Exchange Commission and post these on its website.

Questions or comments about this procedure should be directed to: conflictminerals@stryker.com 

Our SEC Form SD and Conflict Minerals Disclosure and Report can be accessed through the Investor Relations section of our website.

Since it was founded by Dr. Homer H. Stryker in 1941, Stryker Corporation has been committed to conducting its affairs in compliance with all applicable laws and regulations and the highest ethical standards. Stryker also expects its business partners and suppliers to help to ensure that we continue to meet our commitment to responsible supply chain management. Efforts to eradicate slavery and human trafficking from our supply chain are part of our comprehensive commitment to ethics, compliance with laws and social responsibility.

The California Transparency in Supply Chains Act of 2010 became effective on 1 January, 2012. The act declares that slavery and human trafficking are crimes under state, federal and international law, and requires that retailers and manufacturers doing business in the state of California disclose their efforts to eradicate slavery and human trafficking from their direct supply chain. The statements below are Stryker’s response to this requirement.

1. Stryker will conduct a risk assessment in order to evaluate and address the risks of human trafficking and slavery when we conduct our annual comprehensive assessment of our product supply chain. We do not use a third party for verification.
2. Stryker conducts audits of its suppliers to assess their compliance with its standards for suppliers, including those meant to eliminate trafficking and slavery in supply chains. The verification is not achieved via independent unannounced audits.
3. We require that our direct suppliers certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.
4. We maintain internal accountability standards and procedures for employees or suppliers failing to meet our company standards regarding slavery and trafficking.
5. We plan to provide company employees and management, who have direct responsibility for supply chain management, with training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.