VARIAN MEDICAL SYSTEMS, INC. Supplier Code of Conduct

VARIAN MEDICAL SYSTEMS, INC. Supplier Code of Conduct

VARIAN MEDICAL SYSTEMS, INC. Supplier Code of Conduct This Supplier Code of Conduct, in conjunction with our Code of Conduct, outlines the requirements and expectations for suppliers representing Varian Medical Systems, Inc., and all of its subsidiaries worldwide ( Varian ). Every Varian supplier is expected to uphold the legal and ethical standards of the Varian s Supplier Code of Conduct, and to act in full compliance with the laws, rules and regulations of the countries in which it operates. Violations of this Supplier Code of Conduct will be treated seriously, and may be grounds for disciplinary action, up to and including termination of contracts, in accordance with applicable law. CONTENTS LABOR... 2 HEALTH AND SAFETY... 3 ENVIRONMENT... 3 CONFLICT MINERALS... 3 ETHICAL COMPLIANCE... 4 TRADE COMPLIANCE.... 4 PRIVACY AND INTELLECTUAL PROPERTY... 5 COMPLIANCE MONITORING.... 5 TRAINING, NON-RETALIATION, ANONYMOUS COMPLAINTS.............. 5 CONTACT INFORMATION... 6 1 VARIAN MEDICAL SYSTEMS SUPPLIER CODE OF CONDUCT EC00017 rev 01, effective 16 JUNE 2017

LABOR Fair-Treatment Consistent with applicable employment and labor laws, Suppliers will treat each employee with dignity and respect and will not threaten workers with or subject them to harsh or inhumane treatment, including sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse. Discrimination Suppliers will not discriminate against any employee in its hiring and employment practices on the basis of race, sexual orientation, gender identity, gender expression, domestic partnership, ancestry, marital status, color, age, gender, national origin, disability, veteran status, religion, or any other legally protected characteristics. Voluntary Employment Supplier will not use forced or involuntary labor, including indentured or debt slavery bondage labor, involuntary prison labor, slavery or trafficking of persons. Employment must be voluntary. Child Labor Supplier must comply with all applicable laws regarding minimum employment age. Child labor is prohibited. The minimum age of employees must be the greater of (1) the minimum age allowed by law in that country; or (2) the age for completing compulsory education in that country, whichever is greater. Working Hours, Wages, and Benefits Suppliers will not require employees to work more hours than permitted under applicable laws. Suppliers must comply with all applicable laws and regulations related to wages and work hours and must provide all legally mandated benefits. Suppliers that provide housing must ensure that housing is clean, provide sufficient egress, access to potable water and sanitary facilities. EC00017 rev 01, effective 16 JUNE 2017 VARIAN MEDICAL SYSTEMS SUPPLIER CODE OF CONDUCT 2

HEALTH AND SAFETY Suppliers must provide a clean, safe and healthy work environment for its employees in compliance with applicable laws that minimizes workplace injuries and protects the health, well-being, and safety of all workers. Suppliers must have effective measures to control hazards and protect employees against accidents and occupational diseases. Suppliers must have procedures in place for handling emergencies such as fire, spills, and natural disasters. Suppliers will provide training to ensure employees are educated in health and safety issues. ENVIRONMENT Suppliers must act in accordance with applicable statutory and international standards to protect the environment. Suppliers must seek ways to conserve natural resources and energy, reduce waste, and use the hazardous substances and minimize adverse impacts on the environment. Suppliers must ensure that the products provided meet the requirements of all applicable laws and regulations, such as the Restriction of Hazardous Substances (RoHS) and Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) and labeling laws for recycling and disposal. CONFLICT MINERALS Suppliers whose products contain tin, tantalum, tungsten and gold (Conflict Minerals) are required to report whether these minerals came from a conflict mine in the Democratic Republic of the Congo or surrounding regions. Suppliers are expected to establish policies, due diligence frameworks, and management systems consistent with the Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk-Areas that are designed to prevent the purchase and use of Conflict Minerals, and requiring their suppliers to do the same. 3 VARIAN MEDICAL SYSTEMS SUPPLIER CODE OF CONDUCT EC00017 rev 01, effective 16 JUNE 2017

ETHICAL COMPLIANCE Suppliers are expected to do business in a way that meets the highest ethical standards and must comply with all applicable national, state and/or local laws, regulations, and ordinances. These standards apply to business activities everywhere in the world, even where violations may be considered a way of doing business. Suppliers are required to comply with all applicable anti-corruption laws and regulations of the countries in which they operate, including the U.S. Foreign Corrupt Practices Act (FCPA). In addition, Suppliers must not bribe or provide kickbacks or any other improper payments or gifts to any officer, director, employee, representative or agent of Varian. Suppliers accounting records must comply with applicable laws and be kept in reasonable detail that accurately and fairly represent transactions, assets, liabilities, revenues, and expenses; and not contain false or misleading information. Suppliers must avoid all transactions or relationships that appear to be conflicts of interest. A conflict of interest is a situation where a Supplier, its employees or agents have a private personal loyalty or activity that might conflict with Varian interests, or might appear to do so; or when a Supplier is in a position to improperly use their relationship with Varian for their own personal benefit. TRADE COMPLIANCE Suppliers are expected to comply with all applicable export, import, and trade compliance laws and regulations in the U.S. and all other countries in which Varian does business. When conducting business across borders, Suppliers must be aware of and follow all applicable laws, as well as Varian s trade compliance policies and procedures. EC00017 rev 01, effective 16 JUNE 2017 VARIAN MEDICAL SYSTEMS SUPPLIER CODE OF CONDUCT 4

PRIVACY AND INTELLECTUAL PROPERTY Suppliers will ensure that all employees and business partners confidential and proprietary information are protected. Suppliers will safeguard and use Varian s confidential information only for the purposes agreed with, and permitted by, Varian. COMPLIANCE MONITORING Suppliers will perform periodic internal audit with respect to its compliance with this Supplier Code of Conduct and provide Varian reasonable access to audit and inspect suppliers facilities and programs. Suppliers will implement a corrective action plan for any deficiencies that are found in a timely manner. TRAINING, NON-RETALIATION, ANONYMOUS COMPLAINTS Suppliers should inform and train its employees and contractors with respect to the requirements of this Supplier Code of Conduct. Suppliers should have a process that is communicated to their personnel to support raising any concerns or reporting violations of ethics, policy or law, without fear of retaliation. Suppliers and their employees should promptly report to Varian violations of this Supplier Code of Conduct, ethics, policy or law. Reports can be made to the Varian Ethics and Compliance Program, the Varian Legal Department or via the Varian Confidential Hotline, with the contact information set forth on the following page. 5 VARIAN MEDICAL SYSTEMS SUPPLIER CODE OF CONDUCT EC00017 rev 01, effective 16 JUNE 2017

CONTACT INFORMATION Varian Ethics and Compliance Program For questions about Varian Ethics and Compliance issues email: ethics@varian.com Download the Varian Code of Conduct at: http://investors.varian.com/download/codeofconduct.pdf Varian Legal Department For all matters and issues of a legal nature involving Varian email: legal@varian.com Confidential Hotline Dial 1-800-367-4402 or locate a local toll-free number at http://www.varian.ethicspoint.com The Varian Confidential Ethics and Financial Helpline (the Hotline ) is an online and telephone reporting service operated by an independent private firm. IMPORTANT NOTE: For individuals in certain countries due to local law, the Hotline may only allow reporting of Accounting or Auditing Concerns through the Hotline system. Varian Feedback and Inquiries Varian Medical Systems, Inc. 3100 Hansen Way Palo Alto, CA 94304-1038 Tel: 1.650.493.4000 EC00017 rev 01, effective 16 JUNE 2017 VARIAN MEDICAL SYSTEMS SUPPLIER CODE OF CONDUCT 6