Modern Slavery Statement

Modern Slavery Statement for January 1, 2020 to December 31, 2020

This statement sets out the steps that GenMark Diagnostics, Inc. (“GenMark”) has taken and will continue to take to ensure that modern slavery and human trafficking are not taking place within our business or supply chain.

GenMark has a zero-tolerance approach to any form of modern slavery, including servitude, human trafficking and forced labor.  We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against modern slavery within our business and supply chain.  GenMark expects our suppliers to adopt the same high standards that we adhere to and have fair employment practices.

  1. Our Business
    1. GenMark is a leading provider of automated, multiplex molecular diagnostic testing systems that detect targets to diagnose disease and optimize patient treatment.
    2. GenMark has offices in the United States and Switzerland. GenMark has a subsidiary in the United Kingdom.  The majority of GenMark’s business is conducted in the United States.  Our direct suppliers are primarily based in the United States.  GenMark also utilizes direct suppliers from China, Korea, Lithuania, Costa Rica, Germany, and the Netherlands.
    3. Product and software development are generally conducted in-house by GenMark.
  2. Our Policies
    1. We have several internal policies to ensure we conduct business in an ethical and transparent manner. These include:
      1. Employment policies.
        1. We conduct eligibility to work checks for all employees to safeguard against human trafficking or individuals being forced to work against their will. GenMark does not knowingly use any form of bonded, slave or child labor.
        2. GenMark seeks to comply with all relevant laws and regulations in relation to legal minimum rates of pay and other conditions of employment for workers, such as fair working hours, meal and rest breaks and other conditions designed to enhance employee health and safety.
        3. GenMark treats staff fairly and equitably, including providing written confirmation of their terms and conditions of employment.
      2. Whistleblowing policy.
        1. We have a whistleblowing policy so that all employees, without fear of reprisals, can raise concerns about inappropriate behavior and practices across our business or supply chain.
      3. International Anti-Bribery Policy.
        1. GenMark’s International Anti-Bribery Policy requires GenMark personnel to conduct Company business in accordance with applicable legal and ethical standards and to comply with the U.S. Foreign Corrupt Practices Act (FCPA), and other countries’ anti-corruption/antibribery regimes, such as the U.K. Bribery Act. The FCPA prohibits improper payments or offers of payments to foreign governments and their officials for the purpose of obtaining or retaining business.
      4. Employee handbook.
        1. GenMark’s employee handbook explains our code of business conduct, the manner in which we behave as an organization, and how we expect our employees to act. Specifically, our Employee handbook states GenMark’s intention to adhere to all relevant laws and regulations in relation to non-discrimination, equal opportunity, and sexual harassment.  The handbook further prohibits physical abuse, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation in the workplace.
  3. Steps taken in 2020
    1. Management responsibility and general awareness
      1. GenMark’s Head of Supply Chain will have the primary day-to-day responsibility for the implementation of this policy, monitoring its use and ensuring that the appropriate processes and control systems are in place.
      2. GenMark’s General Counsel is responsible for amending this statement as appropriate.
      3. Raised general organizational awareness. We have commenced training for all appropriate staff to ensure a high level of understanding of the risks of modern slavery and human trafficking and how to increase transparency in our supply chains.
    2. Risk assessment
      1. Conducted a risk assessment, using legal and procurement teams, to determine whether any risks of slavery or human trafficking exist.
      2. Suppliers were rated as being low, medium or high risk based on several factors including the industry and source country.
      3. The risk assessment identified which parts of GenMark’s business and which supply chains are most at risk of modern slavery so efforts can be focused on those areas.
      4. At risk suppliers and GenMark’s temporary staffing agencies (which have been identified as a higher-risk indicator of modern slavery) were specifically requested to sign an Acknowledgement of GenMark’s Anti-Slavery Goals to bring awareness to this issue.
      5. All new material suppliers must confirm that their own business activities and supply chain do not knowingly involve slavery or human trafficking and contract terms will include the right to terminate if issues of non-compliance are discovered.
      6. Included the U.K.’s Modern Slavery Act 2015 within our risk assessments to ensure the risk continues to be flagged, assessed and appropriately addressed.
  4. Steps GenMark will take in 2021
    1. Management responsibility and general awareness
      1. GenMark’s General Counsel will prepare a second annual statement.
      2. Obtain Board approval for this statement.
    2.  Risk assessment
      1. Assessing and interpreting any recent or emerging case law and best practices.
      2. Benchmarking activities against statements and action plans undertaken by similar organizations.
      3. Evaluate steps taken in 2020 for effectiveness.
      4. Assess new material third party suppliers to identify potential risks.
    3.  Risk mitigation
      1. Act promptly where a compliance breach has been identified or flagged.
      2. Continue to feed lessons learned back into our risk management process.
  5. Our Performance Indicators
    1. We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking are not taking place within our business or supply chain if:
      1. no reports are received from employees, suppliers, the public or law enforcement agencies to indicate that modern slavery practices have been identified.
  6. Approval of This Policy
    1. This statement has been approved by GenMark’s Senior Vice President, General Counsel and Secretary.
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