NxStage Statement Against Slavery and Human Trafficking

The California Transparency in Supply Chains Act of 2010

The California Transparency in Supply Chains Act of 2010 requires manufacturers and retailers doing business in the State of California to disclose information regarding their efforts to eradicate slavery and human trafficking from their direct supply chains.

The U.K. Modern Slavery Act of 2015

The U.K. Modern Slavery Act of 2015 requires companies over a certain size that conduct business in the U.K. to publish a slavery and human trafficking statement each year and disclose what actions have been taken to combat modern slavery.

NxStage Medical, Inc.’s Code of Business Conduct and Ethics

NxStage Medical Inc. endeavors to conduct business, as outlined in our Code of Business Conduct and Ethics, (the “Code”) in compliance with laws and standards set by federal, state, and industry regulations, and is committed to having business relationships with suppliers who share the Company’s dedication to conducting business in a legal and ethical manner. As an extension of our business, we have the same expectations of our suppliers.

As a matter of NxStage policy, and consistent with suppliers’ legal requirements, all NxStage suppliers are obligated to comply with all applicable laws, codes and regulations of the countries, states and localities in which they operate. This includes the laws prohibiting human trafficking and slavery within the country or countries in which they do business.

NxStage assesses conformance to these obligations and expectations with efforts that include:

• Supplier Assessments. Where possible, NxStage requests that suppliers complete a supplier assessment questionnaire to, among other things, evaluate risks of human trafficking and slavery. NxStage reviews these assessments. This analysis is not conducted by a third party.
  
  
• Key Supplier Audits. Where possible, NxStage evaluates key suppliers’ compliance with NxStage’s standards prohibiting human trafficking and slavery in tandem with announced audits that are conducted by NxStage. These audits are not conducted by a third party.
  
  
• Supplier Agreements and Certifications. NxStage has purchase order terms and conditions that are signed by most of its suppliers that require suppliers to certify that materials incorporated into all orders placed, manufactured and shipped to NxStage Medical, Inc. comply with the laws prohibiting human trafficking and slavery of the country or countries in which they are doing business. If NxStage learns of non-compliance issues, NxStage will communicate them to the supplier(s). NxStage would then expect suppliers to take corrective actions to address these issues and keep the Company informed of their actions.
  
  
• Procurement Professionals Training and Accountability. NxStage provides training on human trafficking and slavery to employees responsible for supply chain management, and requires employees to report all suspicions of improper conduct at any supplier. NxStage requires all employees to comply with our Code, and we train all employees on the Code annually, at a minimum. Consistent with our Code, NxStage employees are expected to report violations or possible violations of our Code and/or these supplier obligations either directly or on the toll-free HOTLINE telephone number (Domestic: 800-893-9798) or (International:  888-475-2418). NxStage employees who violate our Code and/or other relevant policies are subject to disciplinary action up to and including termination of employment.

Confirmed January 2019

California Transparency in Supply Chains Act & UK Modern Slavery Act Statement