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, including Insulet International Limited (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 fiscal year 2025. This Statement also includes disclosures required by the California Transparency in Supply Chains Act.

This Statement applies to Insulet Corporation and Insulet International Limited, which is the sales and marketing affiliate of Insulet Corporation in the United Kingdom.

The Statement sets out the steps that Insulet has taken during its fiscal year 2025, 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 behavior, reflects dealing fairly in business, upholds labor 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; and
• 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

Insulet is headquartered in Acton, Massachusetts, with additional offices in other parts of the U.S. and in Australia, Canada, China, England, France, Germany, Spain, Malaysia, Mexico, the Netherlands, the UAE and Saudi Arabia. Insulet’s products are currently available in 25 countries, and Insulet is actively working to reach more customers every day. Insulet manufactures its products at its own manufacturing facilities in Acton, Massachusetts (United States) and Johor Bahru (Malaysia), as well as through a contract manufacturer in China. Insulet also has a component manufacturing facility in California (United States).

Steps Taken to Address Modern Slavery Risks

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

• implementing policies and internal governance procedures (see ‘Policies and Governance’ below);
• mandating modern slavery risk-related training (see ‘Training’ below);
• conducting due diligence and risk assessments on third parties (see ‘Due Diligence, Risk Assessment and Management’ 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 labor and employment laws, applicable industry codes and high ethical standards. The Code is approved by Insulet’s Board of Directors (“Board”). Its implementation is overseen by both Insulet’s SVP, General Counsel and VP, Chief Compliance Officer. The Code represents a single set of values, rules, standards, and principles applicable to employees working for, or on behalf of, Insulet, wherever located worldwide.

Supplier Code of Conduct: 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 our Supplier Code of Conduct, and it underpins our supplier management and procurement practices. The RBA Code (and by extension, our Supplier Code of Conduct) (“Supplier Code”) is updated every five years to ensure it adheres to international norms and incorporates stakeholder feedback. 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 Labor Organization’s International Labor Standards, Organization for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises, ISO standards, and many more. The Supplier Code is available in over 25 languages and was most recently updated in January of 2024.

Human Rights Statement: The Insulet Human Rights Statement (“Statement”) outlines key principles that are reinforced in our employment, ethics, and procurement policies and are designed to respect human rights within our organization and value chain. The Statement aligns with international standards, including the United Nations Universal Declaration of Human Rights, the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work, and the Ten Principles of the United Nations Global Compact. This Statement is available on the Insulet website. Insulet is committed to respecting the rights of vulnerable groups, including those vulnerable to the risks of forced labor and modern-day slavery.

Conflict Minerals Policy

Insulet has adopted a Conflict Minerals Policy that outlines to suppliers and customers our commitment to responsible sourcing of 3TG (tin, tantalum, tungsten, gold) throughout our supply chain. The Conflict Minerals Policy is publicly available on our website at: https://investor.insulet.com/ESG

Contracts

As part of its contractual arrangements with suppliers and distributors, Insulet seeks to obtain commitment from its counterparties that they comply with applicable laws, rules, regulations, codes, ordinances and orders, as determined by governmental or regulatory bodies in the jurisdiction where services are performed. This includes, but is not limited to, those relevant to the protection of workers and/or employees that Insulet’s counterparties engage in relation to the performance of the services for Insulet.

The Supplier Code is integrated into our standard supplier contract template for direct material suppliers to strengthen supplier alignment with our Environmental, Social and Governance (“ESG”) expectations.

Governance

The Nominating, Governance, and Risk Committee (“NGR Committee”) of the Insulet Board of Directors oversees Insulet’s sustainability approach. Insulet’s Sustainability Reporting Steering Committee provides managerial oversight of our sustainability disclosure and adherence to regulatory compliance.

Insulet’s Vice President of Global Sustainability and Chief Sustainability Officer (“CSO”) reports to the Board annually and to NGR Committee generally twice a year to share our progress and enhance the Board’s knowledge of sustainability strategies and practices.

The NGR Committee also monitors Insulet’s risk assessment and management process. The NGR Committee receives periodic updates on certain key enterprise risks and opportunities from Insulet’s Vice President, Internal Audit & ERM, and Insulet’s Vice President, Chief Compliance Officer. The NGR Committee also meets with other members of management responsible for risk in their respective business functions.

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

Training

Employees

All employees are required to undergo ethics training and to certify adherence to the Insulet Code.

Insulet also focuses certain employee training on Insulet functions that interact regularly with suppliers, such as procurement, supplier quality, supplier engineering, and operations leadership. During 2025, the Supplier Responsibility team developed and delivered training for new employees in relevant functions to ensure awareness of our program. This includes education on the Supplier Code, and equipping employees to identify and mitigate supply chain risks.

Suppliers

In addition to the training sessions described above, Insulet also encourages suppliers to attend local Supplier Code training sessions on relevant topics for their specific geographies.

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 and improves these procedures.

Owned Operations

As Insulet continues to expand its global operations, mitigating the risks of forced labor is a key priority.

Supply Chain

Insulet sources components, materials, commodities and services through a broad supplier network. Insulet’s supply chains include both direct and indirect suppliers who provide a range of products and services. Insulet also partners with distributors in certain countries where our products are commercially available to our customers.

Insulet regularly makes suppliers aware of our Supplier Code and drives adherence to it through various activities including questionnaires, contract language, audits, and training. Insulet also monitors newly evolving regulations in countries in which it operates and works with suppliers and internal teams to ensure it meets those requirements.

Insulet follows a risk-based approach using country level risk as one indicator to conduct assessments that include onsite observations, worker interviews, and document review. Insulet focuses on a continuous improvement approach that allows its suppliers to focus on remediation and to integrate the Supplier Code into their operations for long-term impact.

Insulet aims to partner with suppliers committed to conducting business in accordance with its Supplier Code. The Procurement and Sustainability teams are continuing to work closely to incorporate environmental and social factors into supplier selection and management processes to identify and mitigate modern slavery risks. Some examples include:

• Insulet continued to expand audit coverage via the RBA Validated Assessment Program (“VAP”). In 2025, Insulet requested additional RBA VAP reports from suppliers to build on the due diligence performed in previous years. The RBA VAP sets standards for on- site environmental and social compliance criteria, and it facilitates shareable audits conducted by independent firms. Insulet received and reviewed recent1 RBA VAP audit reports for 39% of the supplier facilities that Insulet identified as in-scope and high-risk.2 Insulet’s Procurement team is working closely with the relevant suppliers to address any identified issues. In Insulet’s audit activities, it continues to pay particular attention to indicators of forced labor in recruitment practices. Insulet strictly prohibits all types of forced labor, including worker-paid fees, and expect Insulet’s suppliers to cover or reimburse all recruitment costs for its workforce rather than pass them on to workers.
• As Insulet continues to evaluate potential suppliers for its manufacturing facility in Malaysia, the Sustainability and Procurement teams are actively engaging with suppliers to support their efforts to prevent and mitigate potential human rights risks, including risks related to forced labor in their recruitment and employment practices and, where necessary, Insulet will pursue remediation.

Distributors

Insulet has a standardized due diligence process for vetting prospective distributors of its products. The due diligence process serves to better inform Insulet about who the distributor is and what risks that distributor may create for Insulet. Insulet’s due diligence process is risk- based, meaning that distributors exposing Insulet to a greater potential risk, receive greater scrutiny. In addition to broad ethics and compliance screening, the due diligence also focuses on exposing ESG risks. At a minimum, all distributors must certify that:

• They have never been accused, investigated, fined, convicted, or received any administrative complaints from any government agency related to misconduct involving human rights, modern day slavery, underaged/forced labor, workplace safety/health or similar practices; and,
• They have never been challenged or faced criticism by NGOs or media in general in relation to human rights or modern-day slavery concerns.

Distributors ranked as medium or high-risk, will undergo enhanced due diligence. This involves commissioning intelligence research – done using media searches as well as a summary of NGO actions from a dedicated ESG data source – focused on exposing integrity risks, including unethical employment practices and modern slavery issues.

Distributors classified as medium or high-risk are subject to additional requirements to repeat the due diligence process. Distributors that are classified as medium risk must undergo Insulet’s due diligence process every three (3) years from the date of completion of the last due diligence. High-risk Distributors will repeat Insulet’s due diligence process every two (2) years.

Reporting and Investigating Concerns

Insulet aims to maintain an environment where individuals have a way to voice their concerns about possible breaches of Insulet’s Code and other Insulet policies, as well as suspected violations of country laws and regulations. Insulet has a dedicated ‘Speak Up’ programme that is accessible to employees through an internal Insulet intranet page.

Through its Compliance and Ethics Hotline and Online Portal, Insulet encourages employees, customers, and other interested persons to report ethical concerns. 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 misconduct allegation. In 2025, Insulet received no allegations or reports of modern slavery violations.

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

This Statement was approved by the Board of Insulet Corporation on May 21st, 2026