Labour Standards Assurance System Policy

Bausch + Lomb, established in 1853, has been at the forefront of many of the visionary innovations in eye health from optical lenses to contact lenses, from eye drugs to surgery. We have over 150 years of experience in delivering ophthalmic products and services globally and our history of innovation continues today as we invent new materials, engineer new technologies, and create pioneering ways to help people see better. Bausch + Lomb is part of the Bausch Health group of companies and its ultimate parent is Bausch Health Companies, Inc.

The Bausch Health group is a multinational, specialty pharmaceutical and medical device company anchored by a collection of world-class products, Bausch + Lomb is positioned to continue its relentless pursuit of its mission to help patients across the world to see better, to live better, in order to see better to live better. Bausch + Lomb currently delivers ophthalmic products and services to approximately 3,500 customers in the United Kingdom. Our customer base has been essential in enabling Bausch + Lomb to pioneer new technology in this arena and continuously improve our systems in the last ten years. Bausch & Lomb U.K. Ltd (“Company”) comprises of 4 product and service lines:

1. Cataract, Vitreoretinal and Refractive Surgery: Our state of the art Phacoemulsification and Vitreoretinal systems are both the building blocks of this service pillar as well as the driving force in technology innovation. We also offer a full suite of products including intraocular lenses and delivery systems featuring the EyeCee One, enVista®, SofPort® and Akreos™ brands of IOLs.
2. OTC and Optometry Products: Our contact lens offerings span the entire spectrum of wearing modalities and include such well-known brand names as Biotrue®, PureVision®, SofLens®, Boston® and Optima®. Our lens care products include the ReNu® brand of chemical disinfectants for soft contact lenses as well as the Boston® line of products for cleaning GP contact lenses.
3. Pharmaceuticals: Our products treat a wide range of eye conditions including glaucoma, eye allergies, conjunctivitis, dry eye and retinal diseases. We offer proprietary and generic medicines available by prescription, over-the-counter eye drops and other medications.
4. Dermatology Products/Aesthetics Devices: The Solta Medical aesthetics business offers a broad selection of aesthetic medical devices that address a variety of conditions, including skin tightening, skin resurfacing, pigmentation conditions, body sculpting and acne.

The Company currently employs today over 150 staff, fostering a growth mindset and ‘can-do’ attitude at a local level, with the backing and resources made available from the wider Bausch Health group. We take pride in a team that is wholly dedicated to working in strong collaboration with each other and sharing knowledge and skills readily in order to further the unified company success.

Resulting from its business operations, the Company acknowledges its obligations towards its customers, employees and the communities in which it works, and has decided to document its policy in relation to labour standards and for this document to be approved by senior management; specifically by the Surgical Business Unit Director and General Manager.

The Company’s Leadership Team define this policy as relevant to the organisation itself, its contractors, subcontractors, suppliers and other parties engaged through the supply chain.

Scope of Policy

This policy applies to the Company and its employees.

Nature and Scale

The Company commits to periodically review this policy in order to continually improve, taking into consideration changes in legislation, and any other requirements to which the Company subscribes, and in order to ensure the adequacy, suitability and continuing effectiveness of the policy.

The Company  recognises the important part businesses can and should play in tackling slavery and its obligations  pursuant to the Modern Slavery Act 2015, the Company  monitors UK and global legislation developments, to ensure continued compliance in preventing exploitation and human trafficking and protecting our workforce and identification of any further opportunities to maintain transparency and compliance throughout its supply chain.  

Specifically, the policy will be routinely reviewed at the Company Leadership Team Meetings.

Minimum Labour Standards

The Company is committed to ensuring there is transparency in its own business and in its approach to tackling modern slavery throughout its supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.

In addition, the Company has identified the following compelling reasons to establish and maintain a comprehensive system of Minimum Labour Standards to guide it in its business operations.

1. ETHICAL RESPONSIBILITIES — the Company acknowledges its obligations towards its customers, employees and the communities in which it works arising from its business operations and wishes to work and trade in an ethical fashion.
2. THREAT TO SECURITY OF SUPPLY — the Company has identified that labour standards abuses in supply chains can pose a risk to the security of supply. Any supply chain partners perpetrating abuses face legal enforcement action which may damage business and interfere with their ability to continue to supply.
3. ADVERSE PUBLICITY AND DAMAGE TO THE COMPANY’S REPUTATION — adverse publicity from the discovery of labour standards abuses in the Company’s supply chain presents reputational and structural risks as follows — (a) income — customers may choose to purchase supplies and services from other providers (b) staff recruitment and retention — staff may choose not to work for a Company associated with any labour standards abuses and this may lead to poor morale in the work place and difficulty in recruitment (c) loss of trust — both with customers and suppliers and also within the wider community.
4. REDUCED QUALITY OF GOODS AND SERVICES — the Company recognises that there is commonly a link between poor labour standards and poor quality of goods and services. To this end, it is in the interest of the Company to ensure its suppliers reach minimum labour standards targets at all times.

The Company is committed to acting ethically and with integrity in all our business dealings and relationships and that all those under our control comply with applicable laws and ethical obligations. To help it identify a defined set of minimum labour standards, the Company has particularly referred to the following resources:-

Social Accountability International’s SA8000 document and the UN’s Universal Declaration of Human Rights.

The Company has identified the following minimum labour standards:

1. Child Labour — the Company does not engage in or support the use of child labour. If the company engages any young workers (eg: on work experience), it will ensure that a suitable risk assessment is carried out and that young persons are not exposed to any hazardous conditions, or in any case work more than 8 hours per day.
2. Forced & Compulsory Labour — the Company shall not engage in or support the use of forced or compulsory labour, or bonded or involuntary prison labour. Employees are free to leave upon reasonable notice.
3. Health & Safety — the Company shall provide a safe and healthy workplace environment and shall take effective steps to prevent potential accidents and injury to employees’ health by minimizing, so far as is reasonably practicable, and in co-operation with its employees, the causes of hazards inherent in the workplace. All employees will receive safety and job specific instructions during the course of their employment with the company. Employees shall have access to clean sanitary facilities and drinking water. Responsibility for implementing the Health & Safety element of this policy is assigned to the General Manager and Leadership Team.
4. Freedom of Association — the freedom of association is respected and the Company will comply with UK labour relations legislation in this regard.
5. Discrimination — the Company shall not engage in or support any discriminatory practices in hiring, remuneration, access to training, promotion, termination or retirement based on race, national or social origin, caste, religion, gender, sexual orientation, political affiliations, age or other conditions that could give rise to discrimination. The Company has an Equal Opportunities and Diversity Policy which is shown to all new employees at induction.
6. Disciplinary Practices — the Company shall treat all employees with dignity and respect. The Company shall not engage in or tolerate the use of corporal punishment, mental or physical coercion or verbal abuse of personnel. No harsh or inhumane treatment is allowed.
7. Working Hours — the Company shall comply with applicable laws and industry standards on working hours and holiday entitlements. The Company’s normal working hours do not exceed 48 hours per week, and overtime hours do not exceed 12 hours per week. The Company ensures all employees have the legal right to be employed in the UK.
8. Remuneration — the Company shall comply with national laws and regulations with regard to wages and benefits. All work related activities are carried out on the basis of a recognised employment relationship established according to national law and practice.

The Company also commits to:-

• Ensure that all its key contractors, sub-contractors and suppliers are aware of this policy.
  
• Make available sufficient resources for the implementation of this policy.
• Complete an annual assessment utilising the UK Government Modern Slavery Assessment Tool and take appropriate actions based on the subsequent bespoke report.
  
• Maintain a ‘green’ status as defined by the UK Government Modern Slavery Assessment Tool.
  
• Compliance with relevant legal and other requirements to which it subscribes.
  

We make a clear annual Anti-slavery Statement setting out the steps we have taken to ensure slavery and human trafficking is not taking place in our supply chains and to demonstrate that we take our responsibilities to our employees, people working within our supply chain and our customers seriously. We make this Anti-slavery Statement together with this Policy available on our website.

Training on this policy, forms part of the induction process for all individuals who work for the Company, and annually thereafter. In addition, this policy shall be available internally via HR SharePoint and shall be publicly available on the Company’s website. This policy shall also be communicated to key suppliers, contractors and business partners, specifically those that are connected to the UK Surgical Business.

Ben Hesketh
General Manager, UK&I
June 2021 — Version 5