Disclosure under the California Transparency in Supply Chains Act of 2010
Ventana has requested that all key suppliers that supply materials for use in our products comply with the Roche Supplier Code of Conduct, or an equivalent code of conduct. The Roche Supplier Code of Conduct provides, among other things, that our suppliers may not use any form of child, involuntary, or slave labor in the manufacture of the goods that are incorporated into products we sell. Prior to engaging a supplier, Ventana performs a risk-based assessment, which is not conducted by a third party and may include supplier questionnaires and audits of supplier facilities. We conduct routine announced audits of suppliers on a periodic basis to confirm compliance with supplier performance and quality standards, which may include issues related to child, involuntary or slave labor in the supply chain. We have supply agreements, quality agreements and/or purchase order terms and conditions with all of our direct suppliers, which include certification and agreement to comply with all laws and regulations of the countries in which they are doing business. If a supplier is found to have used child, involuntary, or slave labor in the manufacture of products supplied to us, we will cancel all outstanding orders with such supplier.
All Ventana employees, including employees responsible for supply chain management, are required to comply with the Roche Group Code of Conduct and participate in training on the requirements of the Code, including prohibition of forced and child labor. Ventana is in the process of developing training on human trafficking and slavery for employees, product buyers, and management who have direct responsibility for supply chain management, which will include awareness of such risks in the supply chain and efforts to mitigate those risks. Any employee who fails to abide by our procedures regarding child, involuntary, or forced labor will be subject to disciplinary action, including potential termination.