California Supply Chains Act

Introduction

This Statement is made pursuant to the California Transparency in Supply Chains Act 2010 and constitutes Insulet’s slavery and human trafficking statement for calendar year 2021.

This Statement applies to Insulet Corporation (incorporated in the United States).

The Statement sets out the steps taken by Insulet during 2021 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 – these principles are outlined within Insulet’s Code of Business Conduct and Ethics;
• Delivering high-quality products to customers while focusing on the social and environmental responsibility of its operations and supply chain.
• Making year-on-year progress to improve practices to combat slavery and human trafficking.

Insulet expects its employees, suppliers, and distributors to do the same.

Insulet’s Business

Insulet is primarily engaged in the development, manufacture, and sale of its proprietary Omnipod® line of products. Those products include the Omnipod DASH® Insulin Management System ("Omnipod DASH System”) for people with diabetes who are insulin-dependent and the Omnipod® 5 Automated Insulin Delivery System ("Omnipod 5 System”) for people with type 1 diabetes aged six years or older.

As of December 31, 2021, Insulet has facilities in Canada, China, France, Germany, Mexico, the Netherlands, the United Kingdom, and the United States. Insulet manufactures its products’ components both at its own manufacturing facility in Acton (Massachusetts, United States), as well as through contract manufacturers in China.

Policies and Governance

Policies

Insulet’s Code of Business Conduct and Ethics provides guidelines for all employees, officers, and directors to perform their duties ethically and fairly. Insulet expects every employee to act in compliance with applicable laws and regulations when working with suppliers, business partners, healthcare professionals, customers, and competitors.

In 2021 Insulet expanded its efforts to promote responsibility within its supply chain by joining the Responsible Business Alliance (RBA), the world’s largest industry coalition dedicated to improving social, environmental, and ethical conditions in global supply chains.

As part of this membership, Insulet adopted the RBA Code of Conduct as Insulet’s Supplier Code of Conduct (the “Supplier Code”). The requirements set out in the Supplier Code reference international norms and principles, including the United Nations Guiding Principles on Business and Human Rights, the United Nations Universal Declaration of Human Rights, International Labor Organization Standards, Organization for Economic Cooperation and Development Guidelines for Multinational Enterprises, ISO standards, and others. The Supplier Code encourages suppliers to go beyond legal compliance to advance social and environmental responsibility and business ethics and includes best practice standards around modern slavery and human trafficking such as a commitment to a zero recruitment fee policy.

Governance

Insulet’s Chief Sustainability Officer (“CSO”) and the Global Sustainability Function are responsible for Environmental, Social and Governance (“ESG”) and lead a comprehensive sustainability strategy, to establish and achieve forward-looking goals. Our three strategic Sustainability pillars — Resilient Operations, Sustainable Product Innovation, and People and Communities — form the foundation of our integrated sustainability approach.

Insulet’s Nominating, Governance, and Risk Committee is responsible for reviewing ESG performance and reporting and maintains oversight of ESG risks at the highest level. The CSO reports to the Nominating, Governance, and Risk Committee on the Company’s ESG progress and initiatives twice a year.

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, Compliance, and other relevant functions to build out robust practices to identify and address modern slavery risks.

Risk Assessment and Management

Insulet believes that the risk of modern slavery among its directly employed staff is low. This is due to several factors, including the highly regulated nature of its industry and countries in which Insulet has direct operations, as well as the work itself being undertaken in controlled environments with established policies and processes.

In the 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 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. The Procurement and Sustainability teams are continuously reviewing opportunities to further incorporate environmental and social factors into supplier selection and management processes to identify and manage modern slavery risks.

Training

Insulet provides training to all new employees on its Code of Business Conduct and Ethics. Refresher training is done on an annual basis and whenever there are any material updates to the Code of Business Conduct and Ethics.

During 2021, Insulet’s new Supplier Code was communicated internally to the Procurement team, and externally to suppliers.

Reporting and Investigating Concerns

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 Chief Compliance and 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. In 2021 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.

Updated June 21, 2022