Supplier Code of Conduct

Letter from Group President

Viju Menon

At Stryker, improving healthcare is at the core of our work. We develop innovative products and services, and partner with our customers to improve the quality of life for patients worldwide. To achieve this mission, we need to build strong partnerships based on shared values and a commitment to ethical and responsible practices.

Our Supplier Code of Conduct defines our expectations for all suppliers who partner with us. It reflects our core values—Integrity, Accountability, People, and Performance—and lays the foundation for a resilient, ethical, and sustainable supply chain.

By partnering with suppliers who are equally committed to excellence, we can advance healthcare and create a positive impact for patients, communities, and the planet.

- Viju Menon, Group President, Global Quality and Operations

Overview

Stryker Corporation and its affiliates (collectively "Stryker," "our," or "us") are committed to conducting business in an ethical and legal manner. We have the same expectations for the companies that partner with us. Therefore, we strive to select suppliers and manufacturers (collectively "Suppliers," "you," "your," or "their") who are as committed to integrity, accountability, people, and performance as we are. While Suppliers operate as independent entities, their conduct can impact our business, reputation, and the workers and communities within our supply chain.

Supplier Responsibility

This Supplier Code of Conduct ("Code") outlines our expectations for all Suppliers. Stryker may engage in monitoring activities or targeted assessments to verify compliance with this Code and will partner with Suppliers to drive continuous improvement where necessary.

In addition to fulfilling contractual obligations, Suppliers must:

• Ensure their subsidiaries, affiliates, employees, agents, subcontractors, and sub-suppliers (collectively "Representatives") understand and comply with this Code.
• Monitor their operations and supply chain for compliance with this Code.
• Mitigate and remediate any actual or potential risks of non-compliance with this Code.

Legal, Regulatory, and Standard Compliance

Suppliers must comply with all laws applicable to Suppliers and the services and products they provide, and meet the highest standards of their respective industries. In addition, Suppliers must:

• Support Stryker in complying with our obligations, including legal requirements, when requested, even if those requirements do not directly apply to Suppliers.
• Conduct due diligence in their operations and supply chain to ensure compliance with all applicable laws and this Code.

Business Integrity

Suppliers must conduct business interactions and activities in an ethical and legal manner.

Fair Competition

Suppliers must compete fairly, ethically, and legally for all business opportunities and comply with all antitrust and fair competition laws. Bid rigging, price fixing, price discrimination, or other unfair trade practices are strictly prohibited.

Marketing and Sales

Suppliers must accurately represent their products and services and comply with all applicable regulatory and legal requirements governing the marketing and sale of their products and services, including those set forth by the U.S. Food and Drug Administration (FDA).

Fair Dealing

Suppliers must treat customers, suppliers, competitors, auditors, employees, and regulatory or government officials fairly. It is prohibited to take unfair advantage of anyone by manipulating, concealing, misrepresenting, or abusing information.

Improper Payments

In accordance with our Improper Payments Policy, Suppliers must not make or accept improper payments to influence business decisions or gain an unfair advantage. "Improper" means any act that is intended or appears to influence business decisions or gain an unfair advantage. Suppliers must not offer gifts or entertainment to our employees that could influence or impair judgment (e.g., sporting events, theatrical performances).

Conflicts of Interest

Suppliers must take steps to identify, avoid, disclose, and manage any actual or potential conflicts of interest, including those with your customers, government entities, or with Stryker employees or their relatives.

Insider Trading

Suppliers must not buy or sell securities of Stryker or other companies based on non-public information that could affect investors' decisions.

Intellectual Property

Suppliers must respect Stryker's intellectual property rights, including patents, trademarks, copyrights, and similar rights, and comply with all requirements governing their use.

Confidentiality

Suppliers must protect Stryker's confidential and proprietary information and must not disclose it to third parties without prior written consent. Confidential information may include, but is not limited to, financial and sales data, technical and product information (including samples), business strategies, and research and regulatory information. Suppliers must also refrain from providing Stryker with any third-party confidential information without first obtaining the appropriate consent from the relevant third party.

Reporting and Records

Suppliers must maintain and report all information accurately and truthfully. Suppliers must not sign or submit any document or statement that they know or have reason to believe is false (whether directly or indirectly on behalf of you or Stryker). All records and reports must be created, retained, and disposed of in accordance with applicable legal and regulatory requirements.

Unauthorized News/Publicity

Suppliers must not issue any statement, advertisement, or other public communication (including social media content) that refers to Stryker without our prior written authorization. This includes our name, logo, products, parts, designs, relationships, or any other non-public information.

Data Privacy

Suppliers must process all personal information in accordance with applicable data protection and privacy laws. Suppliers must respect individual privacy and implement appropriate technical and organizational measures to protect personal information and prevent unauthorized access, alteration, or loss.

Information System Security and Use

Suppliers must comply with all applicable requirements, including our Acceptable Use Policy and procedures for maintaining password, confidentiality, and security. These requirements are a condition of providing products or services and accessing our internal systems, networks, or facilities. Technology provided by Stryker may only be used for authorized, business-related purposes.

Quality

Suppliers involved in the supply, manufacture, packaging, repackaging, testing, storage, and/or distribution of materials/products used in or incorporated into Stryker products must establish and maintain an effective Quality Management System (QMS). Suppliers must also support regulatory audits as required.

A Quality Management System should include, at a minimum, the following methods and processes:

• Delivery of products that meet specifications, requirements, and regulations.
• Identification and timely communication of product quality issues.
• Obtaining formal approval before implementing any changes that impact quality.
• Minimizing the risk of introducing counterfeit parts and materials into deliverables.

Business Continuity Planning

Suppliers must assess and address potential risks to their operations through documented business continuity plans, which should be reviewed with us upon request. These plans should identify the Supplier’s critical supply chain for the products supplied and potential risks. Suppliers must promptly and openly communicate any unforeseen events that could disrupt production or product delivery. Collaboration should mitigate any identified risks and effectively address production interruptions.

Trade Compliance

Suppliers must comply with all laws and regulations applicable to the international movement of goods, technology, and software, including customs, export controls, sanctions, and anti-boycott laws. Suppliers must maintain internal controls to, at a minimum:

• Provide complete and accurate information and documentation required for the import and export of goods, including classification, country of origin certificates, invoices, and export authorizations.
• Screen transactions for restricted parties, end-users, and end-uses, and refrain from doing business directly or indirectly with any individual, organization, or country that violates export controls, trade sanctions, and embargoes.
• Retain records and cooperate with information, audit, or assessment requests to verify compliance with trade compliance requirements.

Labor and Human Rights

In accordance with our Human Rights position, Suppliers must conduct business in a manner that respects the rights and dignity of all people.

Forced Labor

Suppliers must prohibit all forms of forced or compulsory labor. This includes any involuntary work or service performed under threat of penalty, including debt bondage and human trafficking.

Child Labor

Suppliers must strictly prohibit the use of child labor. Employment practices must comply with the International Labour Organization (ILO) Conventions or national laws concerning child labor and the employment of young workers (whichever is more stringent). In no event shall the minimum age for employment be less than 15 years, unless the minimum age convention (ILO Convention No. 138) provides for a higher age.

Non-Discrimination

Suppliers must maintain a workplace free from discrimination and harassment. Discrimination based on gender, race, color, ethnicity, national origin, ancestry, citizenship, age, disability, medical condition or history, creed, religion, military service, marital or veteran status, sexual orientation, gender identity or expression, socioeconomic status, or any other characteristic protected by law is strictly prohibited.

Freedom of Movement

Suppliers must ensure that employees have the freedom to leave the workplace or terminate employment without unreasonable restrictions. Suppliers must not retain original copies of employee identification documents, such as passports or other identity documents.

Freedom of Association

Suppliers must comply with all applicable laws and protect employees’ rights to join or not join any lawful association.

Wages, Working Hours, and Benefits

Suppliers must comply with all applicable wage and hour laws and regulations, including those pertaining to minimum wage, maximum working hours per week, overtime, piece rates, and proper employee classification. Suppliers must provide all legally mandated benefits and must not impose disciplinary deductions from wages. When overtime is required, Suppliers must clearly communicate such requirements to employees.

Employment Information

Suppliers must provide employees with clear and accurate information regarding wages, benefits, working hours, and other terms and conditions of employment.

Employment Practices

Recruitment Fees

Suppliers must not require workers to pay recruitment fees, either directly or through third parties, as a condition of obtaining or maintaining employment.

Immigration Law and Proper Documentation

Suppliers must only employ or use workers who have the legal right to work in the jurisdiction where they are employed. Suppliers must review all legally required documentation prior to employing workers to verify future employees’ legal right to work.

Land Rights

Suppliers must prohibit the illegal eviction and dispossession of land, forests, and water resources that communities and individuals rely on for their livelihoods.

Conflict Minerals

Suppliers must conduct due diligence within their supply chains to mitigate the risk of directly or indirectly supporting armed conflict and to support Stryker’s compliance with the Dodd Frank Wall Street Reform and Consumer Protection Act*, EU Conflict Minerals Regulation*, and our Conflict Minerals Policy. Upon request, Suppliers must participate annually in providing Conflict Minerals Reporting Templates (CMRT) and promptly disclose any changes in the status of minerals known to them, including the compliance status of smelters or refiners in their supply chain that impact our products.

Environment

We expect our Suppliers to take concrete steps to improve the sustainability of their operations and reduce their environmental impact.

Environmental Permits

Suppliers must comply with all applicable environmental laws and environmental protection legal requirements and hold all necessary permits, licenses, and authorizations.

Chemical Regulatory Compliance

Suppliers must comply with all relevant chemical-related regulations. In addition, Suppliers must disclose the use of substances on the Restricted Substances List (RSL) for materials supplied to us through our designated data portal and strive to reduce the use of these substances to support Stryker’s compliance.

Chemical-related regulations include, but are not limited to:

• The Stockholm Convention on Persistent Organic Pollutants (POPs Convention)*
• The UN Convention on Mercury (Minamata Convention)*
• The Restriction of Hazardous Substances (RoHS) Directive
• Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation

Waste

Suppliers must handle, control, and reduce waste and wastewater in an environmentally responsible manner. This includes maintaining appropriate systems and processes for storage, recycling, reuse, or disposal. Any waste or wastewater that could have an adverse impact on human health or the environment must be managed, controlled, and/or treated in accordance with applicable laws and the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal (Basel Convention)* before being discharged into the environment. The export and import of hazardous waste and other forms of waste must comply with the Basel Convention.

Emissions

Suppliers must monitor and strive to reduce greenhouse gas (GHG) emissions. Upon request, Suppliers must provide information on their efforts in this area, and:

• Measure and report Scope 1, 2, and 3 emissions.
• Commit to science-based climate targets using recognized frameworks, such as the Science Based Targets initiative (SBTi).
• Cascade these requirements to their own suppliers.

Environmental Degradation

Suppliers must make reasonable efforts to assess the environmental impact of their business activities, including impacts on biodiversity. Where appropriate, Suppliers must take reasonable measures to mitigate or prevent environmental degradation, including impacts on essential human needs such as access to food, water, and sanitation. Suppliers must also monitor and strive to reduce water consumption.

Workplace Health & Safety

Suppliers must ensure that their workplaces are safe and comply with all applicable environmental, health, and safety regulations.

Safe Work Environment

Suppliers must provide a safe, clean, and healthy work environment and comply with all applicable environmental, health, and safety laws, regulations, and requirements. Suppliers must strive to do so by:

• Preventing occupational injuries and safety incidents: Establish and maintain adequate safety standards for workplaces, workstations, and equipment.
• Providing appropriate protective equipment and devices.
• Ensuring appropriate work hours and rest periods to prevent physical and mental fatigue.
• Providing adequate training and instruction to employees for the safe performance of their duties.

Facility Safety

Suppliers must maintain the safety of their facilities at all times. If employing or using security forces, Suppliers must ensure they do not inflict intimidation, torture, cruel, inhuman, or degrading treatment, cause loss of life or bodily harm, or interfere with employees’ rights to organize or exercise freedom of association. Furthermore, Suppliers must comply with our safety procedures when on our facilities.

Emergency Preparedness

Suppliers must develop and maintain emergency plans and response procedures that comply with all applicable laws and regulations. These plans must cover:

• Emergency preparedness, reporting, and notification.
• Evacuation procedures, training, and drills.
• Appropriate hazard detection and suppression equipment.
• Adequate exit facilities at Supplier sites.

Management System

Suppliers must have a management system consisting of appropriate processes, procedures, people, and/or governance structures designed to ensure compliance with this Code and all applicable laws, identify and mitigate operational risks, and promote continuous improvement.

Risk Assessment and Risk Management Processes

Suppliers must establish a process to identify risks and comply with legal compliance for the themes identified in this Code. Suppliers must determine the significance of each risk and implement appropriate procedures and physical controls to mitigate these risks and ensure regulatory compliance.

Communicating Supplier Code of Conduct Requirements to Suppliers

Suppliers’ management systems must include processes for communicating the requirements of this Code to their own suppliers and for monitoring their suppliers’ compliance.

Grievance Mechanism

Suppliers must provide a grievance mechanism that is free from retaliation, intimidation, or harassment, allowing workers and Representatives to anonymously report workplace grievances and violations of this Code. All grievances must be investigated promptly and appropriate corrective and preventive actions taken to prevent recurrence.

Conclusion

Speak Up

We want our Suppliers to speak up when they see or hear anything inappropriate, are unsure how to handle a particular situation, or find any part of this Code unclear.

Seek Guidance or Raise Ethical Questions:

• Speak with your procurement or business contact.
• Use our Ethics Hotline to report issues.
• If you wish to speak confidentially with someone, please call (800) 461-9330.
• If you are located in North America, you can report concerns anonymously by calling (269) 575-0779.

Accountability

In addition to any other rights afforded to Stryker under agreements with Suppliers, Stryker reserves the right to take appropriate action if a Supplier fails to comply with the standards outlined in this Code. Such actions may include, but are not limited to:

• Requiring the Supplier to implement corrective and/or preventive actions to address identified issues.
• Conducting follow-up monitoring or assessments of the effectiveness of any corrective and/or preventive actions.
• Terminating the relationship with the Supplier without notice, liability, or obligation.

We expect Suppliers to act in good faith with Stryker to resolve issues and drive continuous improvement.

Other Information

For more detailed information on Stryker’s company policies, please visit the Corporate Governance page at www.stryker.com.