Policy on Human Trafficking

Human trafficking involves the use of force, fraud, or coercion in exchange for labor, services, or a commercial sex act and hinges on the exploitation of another person.

Bioderm, Inc and its affiliates recognizes human trafficking can occur in many forms and strongly oppose all forms of.  Headquartered in Largo, Florida, BioDerm is one of the nation’s leading manufacturers of proprietary hydrocolloid products for urinary management, securement, infection control and skin protection. The company challenges accepted inferior standards of care by creating products that reduce infection rates, add comfort and reliability, and vastly improve quality of life. Our flagship products for male urinary incontinence are Men’s Liberty™ for the home and Men’s Liberty Acute™ for in-patient settings. Other product ranges include CathGrip® for securement and BioPlus™ and FreeDerm™ for skin protection.

The Company maintains a Code of Conduct (“Code”), which requires all Associates, among other obligations, to act lawfully, ethically, and responsibly in all their business practices, and to comply with applicable laws. New Associates are required to acknowledge their understanding of the Code and commit to adhering to the Code’s policies. The Company requires all Associates to attest to their understanding of, and adherence to, the Code.

The Code also specifically provides that a failure by any Associate to comply with laws or regulations governing the Company’s Code of Conduct may result in disciplinary actions up to and including termination. To further encourage compliance and the reporting of violations, the Company maintains a Compliance Hotline (reporting system) and website, available to Associates as well as Customers, suppliers, and all other business partners. A strict anti-retaliation policy is followed, and reports may be made anonymously, where allowed by local law. All reports are promptly addressed by the Company’s Sr Director of Corporate Compliance and reported up to both our executive team and board of directors.

The Company has no reason to believe that any human trafficking is occurring in any of the Company’s businesses. Nonetheless, the Company has taken the following steps to detect and prevent any violations of applicable human trafficking and slavery laws or conditions that may give rise to a violation:

• Participation in the Blue Campaign developed by the US Department of Homeland Security (DHS).

Blue Campaign:

• • • Serves as the unified voice for DHS’s efforts to combat human trafficking.
    • Educates the public through awareness resources including public service announcements, posters, brochures, and infographics.
    • Partners with state, local, and tribal governments, federal agencies, and non-governmental and private organizations to provide training and resources on recognizing and reporting suspected human trafficking.
    • Uses social medical to communicate with stakeholders and the general public about DHS efforts, how to recognize and report human trafficking, and how to get involved.
• Human trafficking awareness training is provided to all new employee’s and provided companywide annually.
• A dedicated Compliance Department is responsible for investigating and responding to any complaints received through the Compliance Hotline and conducting routine audits to examine supplier risk.
• The Company has adopted a Policy on Human Trafficking and Slavery (the “Policy”) which expressly prohibits human trafficking or slavery in any form.  Anyone violating this policy is subject to disciplinary action up to and including termination and referral to law enforcement.
• The Company will not work with any organization it finds to be knowingly involved with human trafficking or slavery. Bioderm, Inc encourages everyone, including Associates, contractors, and suppliers, to report in good faith any issues or concerns regarding human trafficking.
• Bioderm, Inc Directors and Senior Management are responsible for ensuring that the activities of the Company continue to comply with applicable human trafficking laws. To this end, Bioderm, Inc will continue to provide adequate resources, the commitment of its Associates, training, and investment to ensure compliance.