CZMI’s California Transparency in Supply Chains Act Disclosure

The California Transparency in Supply Chains Act of 2010 (SB 657) requires certain companies doing business in the state of California to disclose the extent of their efforts to address the risk of forced labor and human trafficking in their product supply chains.

Carl Zeiss Meditec, Inc. (“CZMI”) is committed to ensuring that our business practices reflect CZMI’s values and respect for human rights and the environment, as embodied in CZMI’s Code of Conduct. The CZMI Code of Conduct provides further direction to CZMI employees and business partners regarding our standards for ethical business practices and socially responsible industry conduct. As a general principle, we will not tolerate forced labor, human trafficking, or other human rights abuses in our own operations or in our supply chain.

Our existing mechanisms to address operational and supply chain risks are outlined in the sections that follow. CZMI is also in the process of evaluating additional policies and procedures to specifically manage any potential risks of forced labor and human trafficking in our supply chain.

Verification and Auditing. CZMI gives priority to business partners, suppliers and contractors who share our societal and environmental values, and we support their efforts to promote these values through their business activities. We conduct biannual audits of our 35 key suppliers. This in-depth audit process uses CZMI-developed criteria to gather and evaluate a broad range of information on quality and risk factors. As part of our audit process we also evaluate supplier management systems, including those relating to regulatory compliance and supply chain management. At this time we do not specifically screen for the risk of forced labor or human trafficking.

Certification. CZMI direct suppliers are contractually required to comply with applicable laws. While CZMI does not currently require our direct suppliers to certify compliance with any particular subset of laws, it is our expectation that suppliers comply with all applicable labor and anti-human trafficking laws in the countries in which they operate.

Internal Accountability. The CZMI Code of Conduct requires employees (including temporary personnel, independent contractors, independent sales representatives, and distributor representatives) to adhere to company standards and to encourage ethical business practices and socially responsible industry conduct. CZMI evaluates compliance with company standards, including the CZMI Code of Conduct, through our Internal Audit process. See link We also maintain a Compliance Hotline through which any individual may confidentially report suspected violations. Any and all alleged violations of the CZMI Code of Conduct or other compliance policies will be investigated to determine whether corrective action must be taken.

Training. We provide all employees with training on the CZMI Code of Conduct through our “New Employee Orientation Program,” which is completed within 30 days of hire. CZMI does not provide employees or management with training specific to human trafficking or forced labor. However, we are considering options to integrate these topics into our broader employee training program. We plan to collaborate with our internal auditors to add another layer of internal accountability.