2019 Standards Supplement - Medtronic...§ Our Design, Reliability, Manufacturability (DRM) methodology that ensures product quality, safety, and reliability throughout new product

2019ESG DISCLOSURE INDEX

Page numbers correspond to the 2019 Power of Purpose Report.

Our FY19 Integrated Performance Report was prepared in accordance with the Global Reporting Initiative (GRI) Standard Core guidelines ― an internationally recognized standard for reporting on corporate social and environmental responsibility performance. We have reported on aspects related to our 13 material issues and include information and references to our FY19 Integrated Performance Report, financial reports, and corporate governance guidelines.

We also include a Sustainability Accounting Standards Board (SASB) index for the Medical Equipment and Supplies industry.

https://www.medtronic.com/content/dam/medtronic-com/global/Corporate/Documents/2019-integrated-performance-report.pdf

DISCLOSURE ON MANAGEMENT APPROACH TO MATERIAL ISSUES

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ACCESS TO CARE

Definition The availability and affordability of our technology, services, and solutions to people upon applicable regulatory approval or clearance. This centers on our efforts to ensure that Medtronic products are accessible to patients who can benefit from them by removing barriers to affordable treatment and management of disease. It includes working with partners and healthcare systems around the world to develop and share technologies, services, therapies, resources, and expertise.

Disclosure on Management Approach

DMA-aWe are guided by our Mission: to contribute to human welfare by application of biomedical engineering in the research, design, manufacture, and sale of instruments or appliances that alleviate pain, restore health, and extend life.

Efforts to increase access to healthcare are embedded in the day-to-day operations of our entire company. The Medtronic board of directors and Executive Committee have primary responsibility for ensuring that we are maximizing our ability to reach patients who can benefit from our products and therapies. Each business unit and region reports to the board regularly.

The Medtronic Foundation is led by a board of directors that includes senior leaders from across Medtronic business units and regions, as well as Omar Ishrak, chairman and CEO.

Each business unit develops new products, therapies, and programs to reach more people with life-changing care. We work with strategic partners and explore emerging technologies to develop innovative solutions for unmet healthcare needs — including conditions that disproportionately affect people in emerging markets. Guided by our Global Value-based Healthcare Council, we advocate for a fundamental shift toward value-based healthcare models, where payment for products and services is contingent upon their ability to improve patient outcomes relative to the cost.

The Medtronic Foundation contributes to our access strategy by working in partnership with local nonprofits and governments to invest in impactful healthcare projects aimed at improving access for underserved communities.

DMA-bThe accessibility of our products and solutions is critical to our Mission and our business success. Making our therapies accessible to people everywhere is inherent in our growth strategy.

We view access to healthcare as a human rights issue, and support the principle of universal access to health. Our Mission drives us to contribute to human welfare by improving health outcomes, and our access strategy is a key element of this.

Through business and philanthropic activities, we assess local, unmet healthcare needs. We tailor new or existing products, solutions, and therapies to overcome barriers to care and reduce health inequality.

DMA-cWe develop strategies, programs, and business activities designed to maximize the value of our products and solutions and increase access to healthcare. These include our hub-and-spoke healthcare model, Medtronic Care Management Services, Medtronic Integrated Health Solutions, Medtronic Labs, our Patient Access Acceleration Methodology, and value-based partnerships.

We partner with healthcare providers to enhance access by improving local infrastructure and services. We deliver a range of capacity-building initiatives to enrich the skills and understanding of medical professionals and patients.

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Boundaries (GRI 103-1)

Access, and our related impacts, are relevant for all our customers and patients. This includes individuals who are not yet customers or patients, but who could benefit from our products or therapies.

Reference for more information

See our Global Healthcare Access web page or section in our Integrated Report

See our Philanthropy web page or section in our Integrated Report

Related GRI Aspects

SO: Local Communities EC: Indirect Economic Impacts

PRODUCT QUALITY

Definition Our commitment to ensuring quality and safety of our products in relation to all our stakeholders, including patients, customers, partners, investors, and Medtronic employees. This includes systems and processes to ensure safety and reliability at each stage of the product life-cycle, alongside global compliance, post-market surveillance, complaint handling, and corrective action planning activities.


DMA-aAt Medtronic, product quality is everyone’s responsibility, and it is embedded in our culture. We require employees worldwide to obtain our Annual Quality Training certification and we apply Lean Six Sigma principles and use the Medtronic Corporatewide Assessment for Regulatory Excellence (MCARE) to foster continual improvement in our quality systems.

At the highest level, the Quality Committee of the board of directors is responsible for oversight of Medtronic quality programs. In our business, the Global Quality department leads our product quality efforts. Our chief quality and regulatory affairs officer is a member of the Executive Committee.

When we experience a quality problem with one of our products or therapies, we take corrective actions quickly, including initiating voluntary product recalls. We work to understand and resolve the root cause of any problem and have systems in place to prevent recurrence.

We also adhere to regulatory requirements, such as those set by the U.S. FDA, and use MCARE to drive continual improvement in our regulatory compliance systems.

We test the safety and effectiveness of our products through clinical trials. We conduct clinical trials to the highest standards required by international and national regulations, regardless of where the trial is conducted.

DMA-bOur patient-centric approach compels us to put product quality and safety first. Product quality covers each stage of our value chain, including design, manufacturing, pre-clinical and clinical trials, and post-market surveillance. Quality and reliability are important to ensure the safety of all the patients who depend on our products and therapies for their health and well-being.

https://www.medtronic.com/us-en/about/citizenship/adding-value-to-society/global-healthcare-access.html

https://www.medtronic.com/us-en/about/citizenship/adding-value-to-society/philanthropy.html

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DMA-cOur global quality strategy takes a patient-centered approach and ensures that we deliver consistent companywide quality. Specific processes and programs under our Global Quality Strategy include:

§ The Quality Begins with Me program that empowers employees and suppliers to promote excellence and show individual ownership and leadership of quality.

§ Our Design, Reliability, Manufacturability (DRM) methodology that ensures product quality, safety, and reliability throughout new product design and development.

§ The Medtronic Operating System that improves manufacturing and supplier quality by building continuous improvement principles into production through Lean Six Sigma.

§ The First-Time Quality methodology that teaches employees to see the potential for error, develop strong controls, and identify where improvements can have the biggest impact on quality.

§ The Supplier Optimization and Risk Reduction program that enables strategic suppliers to identify and mitigate risks, to ensure that products and processes are designed correctly.

§ The ISO 13485 standard that sets out requirements for quality management systems specific to medical devices.

We share our quality requirements with suppliers via our Supplier Quality Excellence Manual. We support suppliers to meet our standards through:

§ Regular quality audits based on product and supplier risk

§ Continuous improvement programs, facilitated onsite at supplier manufacturing locations

§ Collaborating with suppliers to improve the design, reliability, and manufacturability of components and products

§ Supporting supplier business continuity management planning initiatives — building their capability to proactively identify and mitigate global operational risks


Product quality is relevant across the entire product life cycle. Within Medtronic, we manage product quality in R&D, manufacturing and production, sales, distribution, post-market surveillance, compliant handling, and corrective action planning.

Product quality is relevant to external groups including customers — the medical professionals and patients who rely on our products and therapies.


See our Product Quality web page or section in our Integrated Report

Related GRI Aspects

PR: Compliance PR: Customer Health and Safety PR: Product Labeling

https://www.medtronic.com/us-en/about/citizenship/working-responsibly/product-quality.html

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PRODUCT STEWARDSHIP

Definition Minimizing the life-cycle footprint of our products and packaging through product management and design innovation.


DMA-aOur Environmental, Health, and Safety (EHS) program commits us to continually advance our product stewardship initiatives across the product life cycle to meet customer needs and expectations. We also comply with applicable regulations such as California Proposition 65 and the E.U. Directive on Restriction of Hazardous Substances.

DMA-bOur customers expect us to demonstrate strong environmental stewardship across the life cycle of our products. Developing products uses energy and natural resources and can also create waste. Driven by our Mission, we manage environmental, health, and safety impacts from our products and packaging across our value chain to minimize our environmental impact.

DMA-cMany teams across Medtronic are responsible for product stewardship. These include:

§ The Medtronic corporate EHS Product Stewardship team oversees our program standards for all businesses and regions.

§ Our Sustainability Steering Committee is responsible for evaluating new product stewardship strategies.

§ The Medtronic Sustainable Packaging Working Group is focused on reducing the environmental impact of our packaging.

§ Our Corporate Program Management Team oversees our environmental compliance efforts.

§ Our Hazardous Substance Team comprises personnel from Corporate and across the businesses to prepare for E.U. Medical Device Regulation and analyze other regulations, provide instructions for compliance, develop detailed implementation plans, and evaluate the effectiveness of our compliance programs.


Product stewardship is relevant to our operations, supply chain, R&D, regulatory, quality, and customers.


See our Product Stewardship web page or section in our Integrated Report

Related GRI Aspects

EN: Materials EN: Products and Services

RESPONSIBLE SUPPLY MANAGEMENT

Definition Our practice of collaborating with suppliers to develop long-term relationships that uphold human rights and labor standards in our supply chain, reduce our environmental impact globally and locally, and enhance our reputation.

https://www.medtronic.com/us-en/about/citizenship/promoting-environmental-stewardship.html

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DMA-aWe expect our suppliers to:

§ Follow applicable laws related to governance, environmental responsibility, workplace health and safety, and human rights

§ Meet the minimum social, ethical, and environmental requirements described in our Global Supplier Standards

FY19 marked the beginning of a three-year process to expand our Global Supplier Standards Compliance Program. Our primary aim is to ensure that our top-spend suppliers fully understand and meet our requirements.

§ During this first year, we focused on building the capacity of our suppliers to answer our requests for information comprehensively and consistently.

§ In year two, we will focus self-assessment activities with top-spend direct material suppliers and contract manufacturers. We will conduct onsite audits with those suppliers considered to be at highest risk of noncompliance.

§ In year three, we plan to extend the coverage of the program to more suppliers.

We launched our new monitoring process by sending self-assessment questionnaires to suppliers deemed to have inherent or potential environmental, social, and governance (ESG) risks. This included certain suppliers located in high-risk countries for human rights and environmental compliance, or where vulnerable workers are likely to be employed. We are taking the lessons from these initial 150 self-assessments to build the capacity of our suppliers for future assessments and guide our audit process.

We have a clearly defined process to address noncompliance:

§ We issue compliance improvement requests to ensure that corrective action is taken.

§ We ask category managers to incorporate these requests into supplier continuous improvement plans.

If issues persist, ultimately a review of the business relationship will occur.

Our Supplier Diversity team, Supplier Diversity Steering Committee, and executive management team oversee our Supplier Diversity program. We promote inclusive sourcing through employee training, business unit annual plans, and sponsorship of organizations that develop and promote small and diverse suppliers in the United States.

We require suppliers to responsibly manage and disclose any materials of concern used in our manufacturing processes, final products, or packaging. We provide a Conflict Minerals Report to the U.S. Securities and Exchange Commission, based on an annual supplier survey.

DMA-bOur Responsible Supply Management Program’s mission is to:

§ Uphold human rights and labor standards

§ Reduce our environmental impact globally and locally

§ Enhance Medtronic’s reputation

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DMA-cWe provide suppliers with protocols, training, and support to ensure that regulatory and self-imposed quality standards are consistently met. We also provide comprehensive responsible supply management training to employees in procurement and sourcing roles. The training focuses on labor and human rights issues — including human trafficking and slavery.

Relevant codes, policies, and standards:

§ Our Global Supplier Standards describe the minimum social, ethical, and environmental requirements and expectations of our suppliers. Supplier selection and management processes, supplier agreements, and purchase order terms and conditions all include reference to the Standards.

§ Our Global Human Rights and Labor Standards Policy applies to all Medtronic locations, all Medtronic personnel, and any third-party labor agencies providing employees on Medtronic’s behalf. We strive to:

– Ensure that our suppliers adhere to the minimum standards that are outlined within this policy.

– Conduct our business in a manner that demonstrates a respect for internationally recognized human rights and the dignity of all people.

§ Our Global Anti-Human Trafficking Policy outlines our commitment to a work environment free from human trafficking, slavery, unlawful child labor, and forced labor of any kind. The policy applies to all Medtronic locations and personnel, and any third-party labor agencies providing services to Medtronic. We strive to ensure that our suppliers adhere to the minimum standards that are outlined within this policy.

§ Our Global Code of Conduct applies to employees, officers, directors, and anyone conducting business on Medtronic’s behalf, such as contractors, consultants, and distributors.


Responsible sourcing is relevant to our suppliers, patients, customers, and local communities.


See our Supply Chain Responsibility web page or section in our Integrated Report

Related GRI Aspects

LA: Supplier Assessment for Labor Practices HR: Supplier Human Rights Assessment EN: Supplier Environmental Assessment EC: Procurement Practices EC: Indirect Economic Impacts HR: Human Rights Grievance Mechanisms HR: Non-Discrimination HR: Freedom of Association

https://www.medtronic.com/us-en/about/citizenship/working-responsibly/ethical-supply-management.html

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ETHICS IN SALES AND MARKETING

Definition Ensuring responsible business practices in relation to the marketing, communication, and promotion of our products and services. This includes the monitoring and prevention of corruption, and conflicts of interest in sales-related interactions between our employees and healthcare personnel as well as compliance with global regulations.


DMA-aMedtronic ensures a shared approach to ethics through guiding policies and principles, trainings, ongoing communications, in-person meetings, and ethics monitoring. Employees must adhere to our policies, which are made explicit in our Code of Conduct and communicated through annual training. We also facilitate anti-corruption training, which is completed by new hires upon onboarding and by customer-facing employees every two years. We engage employees through Ethics Circles, dedicated communications, and regular surveys.

The Medtronic Office of Ethics and Compliance (OEC) oversees, monitors, and implements policies and programs related to our legal, compliance, and ethical obligations. The OEC conducts an annual global risk assessment process designed to find high-risk areas for investigation and remediation.

We require that distributors have anti-corruption measures that are in line with our own. We train distributors on our Distributor Code of Conduct as well as monitor and conduct due diligence on global distributors before entering into a new contract or renewing existing contracts.

DMA-bMaintaining the trust of customers, patients, industry partners, healthcare providers, investors, regulators, governments, and employees is critical to our success. Corrupt practices undermine this trust, our Mission-led commitment to integrity, and our business performance. Building trust also requires that we are transparent. Our customers depend on our medical products, services, and therapies, and we must ensure that they are promoted factually, lawfully, and in a way that supports their approved or cleared use.

DMA-cWe promote our products based on their efficacy, quality, safety, price, and approved use. Employees must adhere to this standard and the policies made explicit in our Code of Conduct and AdvaMed’s voluntary Code of Ethics on Interactions with Healthcare Professionals. Our requirements for product marketing are also included in our Global Business Conduct Standards Policy and our Physician Collaboration policy. Additional internal and external policies to help ensure ethics in sales and marketing include:

§ Distributor Code of Conduct

§ Code of Ethics for Senior Financial Officers

§ Code of Business Conduct and Ethics for Members of the Board of Directors

§ Medtronic Donations

§ U.S. Patient Privacy Principles

https://www.medtronic.com/us-en/about/corporate-governance/code-conduct.html

https://www.advamed.org/sites/default/files/resource/112_112_code_of_ethics_0.pdf

https://www.advamed.org/sites/default/files/resource/112_112_code_of_ethics_0.pdf

https://www.medtronic.com/us-en/about/corporate-governance/global-business-conduct-standards-policy.html

https://www.medtronic.com/us-en/about/corporate-governance/global-business-conduct-standards-policy.html

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Individual Medtronic business units maintain internal review processes to ensure that accurate and appropriate product promotion occurs.

The Medtronic Office of Ethics and Compliance (OEC), and the chief ethics and compliance officer (CECO), oversee our formal ethics and compliance program. The chief ethics and compliance officer reports results periodically to the CEO, the Audit Committee, and to the board. Our internal auditing, monitoring, and investigations programs help ensure that our marketing practices comply with Medtronic policies and external regulations. The OEC processes and thoroughly investigates all reported concerns of alleged misconduct. When employees require ethical guidance or have concerns about potential violations, we strongly encourage them to speak up through one of many channels.


Ethics in sales and marketing, and its related impacts, is relevant to all Medtronic employees. It is also relevant to healthcare providers, industry partners, patients, distributors, investors, regulators, and governments.


See our Ethics in Sales and Marketing website or section in our Integrated Report

Related GRI Aspects

SO: Anti-Competitive Behavior SO: Anti-Corruption PR: Marketing Communications

TRIAL DATA

Definition Ethical and responsible conduct related to clinical trials, including transparency of data, ethics in research and development, and clinical data sharing.


DMA-a

Oversight for clinical trials is the responsibility of the chief medical and scientific officer who serves on the Executive Committee. We share information about applicable trials, including the purpose, eligibility requirements, locations, and status, through the Clinical Trials Registry.

The Technology and Value Creation Committee of the board of directors monitors and evaluates our approach to research and development as well as human and animal studies. Full details of committee responsibilities are available in the committee charters on our Corporate Governance website.

DMA-bThe way we collect and evaluate data is a critical component of our commitment to product quality and safety. Reliable and transparent information ensures that our clinical trials are conducted ethically and in alignment with the highest standards for data integrity and analysis. This, in turn, ensures that our products and therapies are safe and effective for the patients who depend on them.

Sharing knowledge about and data from clinical trials contributes to safety, quality, and efficiency —accelerating medical discovery and enabling patients to benefit more quickly. We work with external organizations and peers to improve and scale the way we collect data and evaluate products and therapies through clinical trials.

https://www.medtronic.com/us-en/about/citizenship/working-responsibly.html

https://www.medtronic.com/us-en/about/corporate-governance/overview.html

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DMA-cWe follow rigorous guidelines laid out in our Code of Conduct and Global Business Conduct Standards Policy, and are committed to adhering to all relevant regulations. We also follow international guidelines for clinical research including the Declaration of Helsinki and ISO 14155:2011.


Ethics, transparency, and reliability of trial data are relevant in our R&D operations and the Regulatory and Clinical Affairs departments.

Ethics, transparency, and reliability of trial data are relevant to external groups including customers — the medical professionals and patients who participate in our clinical trials and use our products once they reach market.


See our Product Quality website section in our Integrated Report

Related GRI Aspects

PR: Customer Health and Safety

STAKEHOLDER ENGAGEMENT

Definition Engaging stakeholders throughout the healthcare system, including advocacy groups, employees, governments, hospital administrators, investors, nonprofits and nongovernmental organizations, patients, physicians, regulators, shareholders, suppliers, and the communities where we operate.


N/A


N/A


See the Public Policy and Stakeholder Engagement section in our Integrated Report

See the Sustainability Priorities and Strategies website or section in our Integrated Report

Related GRI Aspects

General Standard Disclosures

DEVICE SECURITY

Definition Protecting patients, customers, and Medtronic from cyberthreats or vulnerabilities that might compromise product safety or patient privacy.


https://www.medtronic.com/us-en/about/citizenship/working-responsibly/sustainability-priorities-strategies.html

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DMA-aMedtronic engages with external organizations and experts to maintain best practice and to provide feedback on developing global product security-related standards. We collaborate with organizations such as the U.S. FDA, the National Health Information Sharing and Analysis Center, and the Advanced Medical Technology Association. We also follow recognized standards such as ISO 27001 and NIST standards.

Employees and vendors play an important role in protecting data and privacy and are required to complete annual privacy training. Vendors must also adhere to our data security and privacy standards, and we review privacy and security risks as part of our vendor assessment process. When we acquire a company, we conduct privacy and security due diligence, implement policies and procedures, and deliver employee training.

Our product security efforts align with regulatory standards, protect patients, and ensure the highest levels of product usability. Our robust security program is managed by the Medtronic Global Security Office and embedded in the full product life cycle by subject-matter experts within each business unit. Medtronic’s security approach and risk management are informed by internal and external medical device security experts, current security practices, as well as rigorous development processes and vulnerability testing.

We encourage physicians, patients, and other interested parties to submit questions or concerns about medical device security matters to Medtronic.com/security. Our global security team tracks, investigates, and responds to these inquiries.

DMA-bDevice security and any other potential threats to patient safety are taken very seriously at Medtronic. Protecting information is critically important for Medtronic, our customers, and, most importantly, the patients who use our products. We have designed our security and privacy programs to safeguard data in a rapidly evolving environment.

DMA-cMedtronic’s Global Security Office oversee our security framework, including relevant initiatives, policies, and programs.

Medtronic has a formally approved companywide Global Product Security Policy that provides guidance on integrating security into product development. This policy governs the overall product security program.

The Quality Committee and the Technology and Value Creation Committee of the board of directors monitor and evaluate our quality systems and processes on an annual basis. Full details of committee responsibilities are available in the committee charters on our Corporate Governance website.


Device security is relevant across the entire product life cycle. Within Medtronic, we manage product quality and security in R&D, manufacturing and production, sales, and distribution.

Device security is relevant to external groups including customers, patients, and the medical professionals who rely on our products and therapies.


See our Ethics in Sales and Marketing website or Data Security and Privacy section in our Integrated Report

See our Product Quality website or section in our Integrated Report

https://global.medtronic.com/xg-en/product-security.html

https://www.medtronic.com/us-en/about/citizenship/working-responsibly.html


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Related GRI Aspects

PR: Customer Health and Safety PR: Customer Privacy

PHILANTHROPY

Definition Philanthropic activities through the Medtronic Foundation, Medtronic product donations, employee volunteering, corporate and employee financial contributions.1

1 Corporate financial contributions are made only to tax-exempt organizations.


DMA-aOur philanthropic programs are an important extension of our work to expand access to our products. Medtronic and the Medtronic Foundation partner with others to make investments based on impact and outcomes for underserved communities.

The Medtronic Foundation is refining its impact assessment framework, with the aim of ensuring that future funding programs maximize positive outcomes.

The Medtronic Foundation is led by a board of directors that includes Medtronic senior leaders, including Omar Ishrak, Chairman and CEO.

Our philanthropic contributions are managed through our corporate charitable giving, Medtronic business divisions, and the Medtronic Foundation.

Medtronic Philanthropy consists of medical education, product donations, and financial (including funding of the Medtronic Foundation) and volunteer contributions. We support employee choice and empowerment to enable Medtronic employees to pursue their personal philanthropic efforts year-round.

The Medtronic Foundation focuses on expanding access to healthcare for underserved people worldwide and supporting healthy communities. Medtronic and the Medtronic Foundation contribute to disaster relief through grants, product donations, and the Medtronic Employee Assistance Fund, which provides grants to employees with unmet financial needs in the wake of natural disasters.

We disclose all donations made to U.S. customers, or organizations affiliated with them, on our Charitable Donations Registry. Our corporate guidelines for charitable giving are outlined in our Charitable Donations Guidelines. They adhere to both our Global Business Conduct Standards Policy and the medical technology industry’s AdvaMed Code of Ethics.

DMA-bWe engage in a range of philanthropic activities to extend essential healthcare access to the people who need it most. We collaborate with local and global partners to accelerate our effort. By focusing on impact, we ensure that the majority of our investments are strategic and drive the impact needed in underserved communities.

DMA-cIn future years, as we shift toward more impact-focused support, we will measure our success not by the amount of money we give, but by the beneficial effect of our contributions.

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Many Medtronic and Medtronic Foundation philanthropic activities apply to Medtronic employees, who are encouraged to give back to their communities through charitable contributions and volunteerism.

Philanthropy is relevant outside of Medtronic to all the communities, or potential communities, where Medtronic and the Medtronic Foundation undertake philanthropic activities.


See our Philanthropy website or section in our Integrated Report

Related GRI Aspects

SO: Local Communities EC: Indirect Economic Impact

POST-MARKET SURVEILLANCE

Definition Ethical and responsible conduct related to post-market surveillance, including transparency of data, data collection, and clinical data sharing.


DMA-aWe work with external organizations and peers to improve and scale the way we collect data and evaluate products and therapies once they reach the market. For example, we:

§ Collect data through our Post-Approval Clinical Surveillance process, in partnership with hospitals, health systems, physicians, clinics, governments, and third parties

§ Fund in-depth post-market clinical studies to further understand the efficacy of specific therapies and product lines

§ Enable customers to provide comments and feedback through our global complaint handling system

§ Work with global regulators and industry stakeholders to improve our post-market surveillance

§ Develop and standardize models to measure and improve patient safety and clinical outcomes

DMA-bThe way we collect and evaluate data once a product or therapy has reached the market is a critical component of our commitment to product quality and safety. It also plays a vital role in our move toward value-based healthcare with a focus on patient outcomes.

Reliable and transparent information ensures that our post-market surveillance activities are conducted ethically and in alignment with the highest standards for data integrity and analysis. This, in turn, ensures that our products and therapies are safe and effective for the patients who depend on them. Post-market surveillance also helps us understand product performance in a real-world setting, measure performance against known complications, and identify potential problems early.


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DMA-cOur post-market surveillance is overseen by our chief medical and scientific officer, who serves on the Executive Committee.

The Quality Committee monitors and evaluates our approach to product quality. Full details of committee responsibilities are available in the committee charters on our Corporate Governance website.


Ethics, transparency, and reliability of post-market surveillance activities are relevant to external groups including the medical professionals, patients, health systems, and insurers that participate in our surveillance activities and that use our products.


See our Philanthropy website or section in our Integrated Report

Related GRI Aspects

PR: Customer Health and Safety

CORPORATE GOVERNANCE

Definition The policies, procedures, and practices that govern our company, including board structure, executive compensation, and accountability.


N/A


N/A


See our Citizenship Corporate Governance website or section in our Integrated Report

See our Sustainability Priorities and Strategies website or section in our Integrated Report

Related GRI Aspects

General Standard Disclosures



https://www.medtronic.com/us-en/about/citizenship/working-responsibly/sustainability-priorities-strategies.html

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TALENT

Definition The recruitment, retention, and development of Medtronic employees. This includes employee training, career management and promotion, and leadership development, in addition to compensation and benefits practices.


DMA-aOur business is knowledge-based, and our success is dependent on attracting, developing, and retaining top, diverse, and collaboratively minded talent. We support our growing workforce through global career development and training programs, career management opportunities, and competitive benefits and compensation practices. Inclusion, diversity, and gender balance in the workforce are also considered priority areas for Medtronic. The Global Inclusion, Diversity, and Engagement (GIDE) team leads the company in building a more inclusive and diverse culture through our Human Resources processes and priorities.

DMA-bOur Mission inspires us to recognize the personal worth of all employees by providing an employment framework that allows personal satisfaction in work accomplished, security, advancement opportunity, and means to share in the company’s success.

DMA-cOur Human Resources department has established programs and policies to attract, develop, and retain a diverse set of talented employees. These include learning and development, leadership programs, employee engagement initiatives, health and safety, compensation and benefits, as well as recognition. Internal and external-facing policies include:

§ Code of Conduct

§ Equal Employment Opportunity Statement

§ Voice Your Concern Policy

The chief human resource officer serves on the Executive Committee and has primary responsibility for talent and culture-related initiatives.

The Medtronic Compensation Committee assists the board of directors in overseeing and evaluating employee benefit plans and stock programs.

Medtronic monitors the effectiveness of talent programs through internal feedback mechanisms including our Organizational Health Survey and performance evaluations.

Medtronic’s Voice Your Concern Line is a website and toll-free hotline operated by a third party that provides employees as well as anyone operating on behalf of Medtronic a place to report and voice concerns. The OEC evaluates all reported concerns and escalates as necessary.


Within Medtronic, our approach to talent is relevant to all current employees.

Outside Medtronic, our approach to talent is relevant to all prospective employees and former employees.

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See our Supporting a Global Workforce website or section in our Integrated Report

See our Compensation Committee Charter website

Related GRI Aspects

LA: Employment LA: Training and Education LA: Equal Remuneration for Women and Men LA: Labor Practices Grievance Mechanisms SO: Anti-corruption

FINANCIAL STRENGTH

Definition Sustainable revenue generation and business growth through disciplined management of financial capital and resources.


DMA-aWe apply rigorous financial discipline as we pursue a growth strategy focused on technology innovation, invention, and disruption. This strategy is scaled with globalization and economic value.

Five fundamental goals drive our financial planning and decision-making:

1. Deliver consistent 4%+ organic1 revenue growth

2. Achieve 40–50 bps annual underlying1 operating margin expansion

3. Target 8% non-GAAP adjusted earnings per share growth over Planning Period

4. Target 80% conversion ratio2 within next 2–3 years

5. Return a minimum of 50% of free cash flow3 to shareholders

DMA-bSound financial stewardship is at the core of everything we do. A financially strong Medtronic benefits the public and private sectors by providing new jobs, infrastructure investments, shareholder returns, and taxes. The financial strength of our business enables us to improve clinical outcomes, expand access to healthcare, and optimize healthcare cost and efficiency.

DMA-cOur financial performance is overseen by the Audit and Finance and Financial Risk committees of the board of directors.

The Audit Committee is responsible for the integrity of our financial reporting, auditing, and compliance. The Finance and Financial Risk Committee has oversight of our financial policies, strategies, and capital structure. Full details of committee responsibilities are available in the committee charters on our Corporate Governance website.

Our shareholders, as owners of our company, have ultimate say in our financial management. Our Investor Relations team has ongoing contact with our shareholders, and we formally communicate with them and invite feedback through quarterly earnings calls and annual meetings.1Organic and underlying are both defined as “excluding the impact of material acquisitions, divestitures, and currency.”2Conversion ratio is defined as: free cash flow (operating cash flows less property, plant and equipment additions) divided by non-GAAP net income.3Free cash flow is defined as operating cash flows less property, plant and equipment additions.

https://www.medtronic.com/us-en/about/citizenship/supporting-a-global-workforce.html

https://www.medtronic.com/us-en/about/corporate-governance/board-directors-compensation-committee.html


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Financial strength is relevant across all our operations in the way that we generate and use financial resources.

Financial strength is relevant outside our business in the way that we generate revenue from our customers, purchase goods and services from our suppliers, and support local communities, including research and development outlays; selling, general, and administrative expenses; and income taxes.


See our 2019 10-K, Corporate Governance and Investor Relations web pages, or our Environmental Impact of our Business section in our Integrated Report

Related GRI Aspects

EC: Economic Performance EC: Indirect Economic Impacts

http://investorrelations.medtronic.com/sec-filings/sec-filing/10-k/0001613103-19-000028


http://investorrelations.medtronic.com/investor-overview?c=76126&p=irol-IRHome

GLOBAL REPORTING INITIATIVE (GRI) INDEX

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GRI-100

INDICATOR TOPIC RESPONSE

102-1 Name of the organization Medtronic Public Limited Company

102-2 Activities, brands, products, and services

Company Overview

2019 Form 10-K

102-3 Location of headquarters 20 Lower Hatch Street, Dublin 2, Ireland

102-4 Location of operations Company Overview

2019 Form 10-K

102-5 Ownership and legal form Medtronic plc is a publicly traded company on the New York Stock Exchange Inc. under the ticker symbol MDT

102-6 Markets served Company Overview

2019 Form 10-K

102-7 Scale of the organization Company Overview

The Economic Impact of our Business

2019 Form 10-K

102-8 Information on employees and other workers

2019 ESG Disclosure Index

102-9 Supply chain Supply Chain Responsibility

102-10 Significant changes to the organization and its supply chain

Company Overview

Supply Chain Responsibility

2019 Form 10-K

102-11 Precautionary principle or approach

Product Quality

Promoting Environmental Stewardship

Sustainability Priorities and Strategies






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102-12 External initiatives Corporate Governance

Supporting a Global Workforce

Ethics in Sales and Marketing


Data Security and Privacy



Product Quality

102-13 Membership of associations

Corporate Governance



Product Quality

102-14 Statement from senior decision-maker

A Message from Omar

102-15 Key impacts, risks, and opportunities


102-16 Values, principles, standards, and norms of behavior


Ethical Business Conduct


Data Security and Privacy


Product Quality


102-17 Mechanisms for advice and concerns about ethics



102-18 Governance structure Corporate Governance

Corporate Governance Website


http://www.medtronic.com/us-en/about/corporate-governance.html

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102-19 Delegating authority Sustainability Priorities and Strategies

102-20 Executive-level responsibility for economic, environmental, and social topics


102-21 Consulting stakeholders on economic, environmental, and social topics



102-22 Composition of the highest governance body and its committees



102-23 Chair of the highest governance body



102-24 Nominating and selecting the highest governance body



102-25 Conflicts of interest Corporate Governance Website

102-26 Role of highest governance body in setting purpose, values, and strategy


102-29 Identifying and managing economic, environmental, and social impacts


102-30 Effectiveness of risk management processes


102-31 Review of economic, environmental, and social topics






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102-33 Communicating critical concerns


102-35 Remuneration policies Corporate Governance


Proxy Statement

102-36 Process for determining remuneration



Proxy Statement

102-37 Stakeholders’ involvement in remuneration

Proxy Statement

102-40 List of stakeholder groups Corporate Governance


102-41 Collective bargaining agreements

Medtronic complies with global laws regarding freedom of association and collective bargaining agreements, including participation in work councils. Around 35% of our European workforce is represented by work councils, and roughly half is covered by collective bargaining agreements with trade unions. Our U.S. workforce is not unionized.

102-42 Identifying and selecting stakeholders


102-43 Approach to stakeholder engagement



102-44 Key topics and concerns raised


102-45 Entities included in the consolidated financial statements

Company Overview

About This Report

2019 Form 10-K


http://media.corporate-ir.net/media_files/IROL/76/76126/Medtronicplc_DEF14A_20180824.pdf




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102-46 Defining report content and topic boundaries


About This Report

102-47 List of material topics Sustainability Priorities and Strategies


102-48 Restatements of information

Any restatements of information and data provided in previous reports are noted throughout this report.

102-49 Changes in reporting Throughout the report

About This Report

102-50 Reporting period About This Report

102-51 Date of most recent report

Our FY18 report was published in November 2018

102-52 Reporting cycle Annual

102-53 Contact point for questions regarding the report

About This Report

102-54 Claims of reporting in accordance with the GRI Standards


102-55 GRI content index 2019 ESG Disclosure Index

102-56 External assurance This report has not been independently verified. We have practices in place to internally validate the data.

103-1 Explanation of the material topic and its boundary


103-2 The management approach and its components


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GRI-200

INDICATOR TOPIC RESPONSE IDENTIFIED OMISSIONS

EXPLANATION FOR OMISSIONS

201-1 Direct economic value generated and distributed


Philanthropy

2019 Form 10-K

201-2 Financial implications and other risks and opportunities due to climate change



201-3 Defined benefit plan obligations and other retirement plans


203-1 Infrastructure investments and services supported


Global Healthcare Access

Philanthropy


203-2 Significant indirect economic impacts

Global Healthcare Access


204-1 Proportion of spending on local suppliers

Supply Chain Responsibility Percentage of the total procurement budget used for significant locations of operation spent on suppliers local to that operation.

The information is currently unavailable. At this time, we do not collect full data on the percentage of the total procurement budget used for significant locations of operation spent on suppliers local to that operation. Medtronic collects total procurement spend at significant locations of operation.

205-1 Operations assessed for risks related to corruption




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205-2 Communication and training about anti-corruption policies and procedures



205-3 Confirmed incidents of corruption and actions taken




2019 Form 10-K

Confirmed incidents of corruption and actions taken

The information is currently unavailable. Medtronic currently tracks the total number of employees terminated for ethics- and compliance-related lapses. In FY18, we looked at best practices among our peers for reporting and classifying ethical concerns. We identified potential improvements in how ethical concerns are categorized and are assessing the feasibility of reporting them in more detail in the future.

206-1 Legal actions for anti-competitive behavior, anti-trust, and monopoly practices

2019 Form 10-K

GRI-300

301-3 Reclaimed products and their packaging materials


302-1 Energy consumption within the organization


302-3 Energy intensity Promoting Environmental Stewardship

302-4 Reduction of energy consumption




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302-5 Reductions in energy requirements of products and services


303-2 Water sources significantly affected by withdrawal of water


305-1 Direct (Scope 1) GHG emissions


305-2 Energy indirect (Scope 2) GHG emissions


305-4 GHG emissions intensity


305-5 Reduction of GHG emissions


307-1 Non-compliance with environmental laws and regulations


308-1 New suppliers that were screened using environmental criteria


Our Global Supplier Standards describe the minimum social, ethical, and environmental requirements and expectations of our suppliers. Supplier selection and management processes, supplier agreements, and purchase order terms and conditions all include reference to the standards.

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308-2 Negative environmental impacts in the supply chain and actions taken

Supply Chain Responsibility — Embedding Sustainabiity and Responsibiity in our Supply Chain

We have a clearly defined process to address noncompliance:- We issue compliance improvement

requests to ensure that corrective action is taken.

- We ask category managers to incorporate these requests into suppliers’ continuous improvement plans.

- If issues persist, ultimately a review of the business relationship will occur.

GRI-400

401-1 New employee hires and employee turnover


401-2 Benefits provided to full-time employees that are not provided to temporary or part-time employees


401-3 Parental leave Supporting a Global Workforce

403-2 Types of injury and rates of injury, occupational diseases, lost days, and absenteeism, and number of work-related fatalities


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404-2 Programs for upgrading employee skills and transition assistance programs


404-3 Percentage of employees receiving regular performance and career development reviews


405-1 Diversity of governance bodies and employees

Corporate Governance Supporting a Global Workforce 2019 ESG Disclosure Index

405-2 Ratio of basic salary and remuneration of women to men


406-1 Incidents of discrimination and corrective actions taken

Total number of incidents of discrimination and corrective actions taken.

The information is currently unavailable. At this time, we do not track discrimination incidents for our suppliers. We do not plan to collect this specific information but expect our suppliers to follow local laws and regulations.

407-1 Operations and suppliers in which the right to freedom of association and collective bargaining may be at risk

Responsible Supply Management Suppliers in which workers’ rights to exercise freedom of association or collective bargaining may be violated or at significant risk.

The information is currently unavailable. Through our Global Supplier Standards Compliance Program we plan to track this information for our suppliers in the future.

408-1 Operations and suppliers at significant risk for incidents of child labor

Suppliers at significant risk for incidents of child labor


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409-1 Operations and suppliers at significant risk for incidents of forced or compulsory labor

Suppliers at significant risk for incidents of forced or compulsory labor


412-2 Employee training on human rights policies or procedures


412-3 Significant investment agreements and contracts that include human rights clauses or that underwent human rights screening

Supply Chain Responsibility Our Global Supplier Standards describe the minimum social, ethical, and environmental requirements and expectations of our suppliers. Supplier selection and management processes, supplier agreements, and purchase order terms and conditions all include reference to the standards.

413-1 Operations with local community engagement, impact assessments, and development programs

Global Healthcare Access The Economic Impact of our Business Philanthropy

Percentage of operations with implemented local community engagement, impact assessments, and development programs.

The information is currently unavailable. At this time, we do not quantify local community engagement activities as a percentage of operations and do not have plans to do so. Our products and therapies are available to patients all over the world. Our efforts to increase access through business and philanthropy are global. In addition, our philanthropic activities focus on where we have the largest employee presence as well as medically underserved communities where we believe we can reduce barriers to care. We collaborate with local governments, health systems, companies, and

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nonprofit organizations to assess local needs and develop locally appropriate healthcare solutions.

414-1 New suppliers that were screened using social criteria

Supply Chain Responsibility Our Global Supplier Standards describe the minimum social, ethical, and environmental requirements and expectations of our suppliers. Supplier selection and management processes, supplier agreements, and purchase order terms and conditions all include reference to the standards.

414-2 Negative social impacts in the supply chain and actions taken

Supply Chain Responsibility We have a clearly defined process to address noncompliance:- We issue compliance improvement

requests to ensure that corrective action is taken.

- We ask category managers to incorporate these requests into suppliers’ continuous improvement plans.

- If issues persist, ultimately a review of the business relationship will occur.

415-1 Political contributions Corporate Governance


416-1 Assessment of the health and safety impacts of product and service categories

Product Quality

417-1 Requirements for product and service information and labeling

Promoting Environmental Stewardship Ethics in Sales and Marketing


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417-2 Incidents of noncompliance concerning product and service information and labeling


417-3 Incidents of noncompliance concerning marketing communications


419-1 Noncompliance with laws and regulations in the social and economic area

2019 Form 10-K


SUSTAINABILITY ACCOUNTING STANDARDS BOARD (SASB) INDEX

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MEDICAL EQUIPMENT AND SUPPLIES

AFFORDABILITY AND PRICING

SASB CODE METRIC RESPONSE

HC-MS-240a.2

Description of how price information (such as average and median) for each product is disclosed to customers or their agents (e.g., group purchasing organizations or consultants)

Partially reported in Adding Value to Society > Expanding Global Healthcare Access

PRODUCT SAFETY


HC-MS-250a.1

Number of recalls issued, total units recalled Partially reported in Working Responsibly > Product Quality

HC-MS-250a.2

List of products listed in the FDA’s MedWatch Safety Alerts for Human Medical Products database

Reported in Working Responsibly > Product Quality

FDA’s MedWatch Safety Alerts for Human Medical Products database

HC-MS-250a.4

Number of FDA enforcement actions taken in response to violations of current Good Manufacturing Practices (cGMP), by type

In FY19 Medtronic received:n Four Form 483snTwo Warning LettersnZero Seizuresn50 recalls (limited to reportable recalls)nZero consent decrees

ETHICAL MARKETING


HC0201-04 Total amount of monetary losses as a result of legal proceedings associated with false marketing claims

Reported in Working Responsibly > Ethics in Sales and Marketing

HC-MS-270a.2

Description of code of ethics governing promotion of off-label use of products


https://www.fda.gov/safety/medwatch-fda-safety-information-and-adverse-event-reporting-program

https://www.fda.gov/safety/medwatch-fda-safety-information-and-adverse-event-reporting-program

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PRODUCT DESIGN AND LIFE-CYCLE MANAGEMENT


HC-MS-410a.1

Discussion of process to assess and manage environmental and human health considerations associated with chemicals in products, and meet demand for sustainable products

Partially reported in Promoting Environmental Stewardship > Product Stewardship

HC-MS-410a.2

Total amount of products accepted for takeback and reused, recycled, or donated, broken down by: (1) devices and equipment and (2) supplies

Partially reported in Promoting Environmental Stewardship > Product Stewardship

SUPPLY CHAIN MANAGEMENT


HC-MS-430a.1

Percentage of (1) entity’s facilities and (2) Tier I suppliers’ facilities participating in third-party audit programs for manufacturing and product quality

Currently, four Medtronic supplier sites participate in the U.S. Food and Drug Administration (FDA) Case for Quality program. Medtronic subscribes to MedAccred — an industry-managed supply chain oversight program. This third-party accreditation focuses on improving process repeatability while reducing nonconformances. We have shared details of the program with suppliers and encourage them to pursue accreditation.

HC-MS-430a.2

Description of efforts to maintain traceability within the distribution chain Medtronic maintains traceability within the manufacturing and distribution chain through either serial or batch control of finished products. We:n Leverage product identification technologies

such as barcoding and radio-frequency identification to track identifying information of products

n Utilize enterprise resource planning (ERP) solutions to support identification and control of products once they leave manufacturing sites — including supporting specific patient tracking if required

Our ERP solutions ensure compliance with regulatory, quality, and customs control requirements.

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HC-MS-430a.3

Description of the management of risks associated with the use of critical materials

Partially reported in Working Responsibly > Supply Chain Responsibility

BUSINESS ETHICS


HC-MS-510a.1

Total amount of monetary losses as a result of legal proceedings associated with bribery or corruption


HC-MS-510a.2

Description of code of ethics governing interactions with healthcare professionals


Reported in Working Responsibly > Ethical Business Conduct

EMPLOYEE DATA SUMMARY

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MEDTRONIC GLOBAL WORKFORCE*†

FY17** FY18†† FY19*** Total 91,656 91,109 90,108 Female 45,174 44,874 44,674

Asia Pacific 12,399 12,873 12,653 Female 5,546 5,568 5,404

Canada 1,612 1,417 1,286 Female 919 806 745

Europe/Central Asia/Middle East/Africa 17,479 17,293 18,377 Female 8,768 8,883 9,216

Latin America 17,722 17,293 16,920 Female 11,025 10,800 10,661

U.S. and Puerto Rico 42,444 41,763 40,872 Female 18,916 18,817 18,648

* Calculated as Average Headcount for the FY. Employee population data expressed here may vary from our 10-K form depending on the time of year in which the data was gathered.

† Some data may be restated from our FY17 and FY18 Integrated Reports due to updated data parameters.

EMPLOYMENT TYPE*

FY18†** FY19††

Support staff 39,459 37,061 Female 23,339 22,088

Professional 41,339 42,472 Female 17,872 18,664

Management*** 9,789 10,041 Female 3,671 3,772

VPs and higher 524 535 Female 143 150



**151 records do not specify gender. ††75 records do not specify gender.***57 records do not specify gender.

**75 employees do not have a job category designation. ††57 employees do not have a job category designation. ***Management positions = managers and above.

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GLOBAL FULL-TIME*†

FY17** FY18†† FY19***

Total 89,681 89,231 88,258 24 and under 5,364 5,323 5,330 25-39 40-54 55-69

41,21233,1709,800

41,33932,8019,631

41,07032,1119,594

70+ 135 137 154

Female††† 43,504 43,290 43,129 Asia Pacific 5,382 5,451 5,330 Canada 896 785 732 Europe/Central Asia/Middle East/Africa 7,603 7,704 7,998 Latin America 11,022 10,799 10,660 U.S. and Puerto Rico 18,601 18,552 18,411



** 0 records have out of bound values so are not included in age breaks. 151 records do not specify gender.

†† 0 records have out of bound values so are not included in age breaks. 75 records do not specify gender.

*** 1 record has out of bound values so is not included in age breaks. 57 records do not specify gender.

††† Numbers by region are based on female employees only.

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GLOBAL PART-TIME*†

FY17** FY18†† FY19***

Total 1,976 1,879 1,850 24 and under 46 32 21 25-39 40-54 55-69

649969303

617951274

611957257

70+ 9 6 5

Female††† 1,670 1,584 1,545 Asia Pacific 164 117 74 Canada 23 21 14 Europe/Central Asia/Middle East/Africa 1,165 1,180 1,218 Latin America 3 1 2 U.S. and Puerto Rico 317 266 238



** 0 records have out of bound values so are not included in age breaks. 0 records do not specify gender.

†† 0 records have out of bound values so are not included in age breaks. 0 records do not specify gender.

*** 0 record have out of bound values so are not included in age breaks. 0 records do not specify gender.


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NEW EMPLOYEE HIRES*†

FY17** FY18†† FY19***

Total 17,608 18,166 17,545 24 and under 4,453 4,363 4,586 25-39 40-54 55-69

9,1023,401640

10,0043,221565

9,5592,927453

70+ 12 13 19

Female††† 8,424 9,211 9,226 Asia Pacific 977 1,085 1,220 Canada 173 127 217 Europe/Central Asia/Middle East/Africa 1,049 1,261 1,225 Latin America 3,750 3,847 4,123 U.S. and Puerto Rico 2,475 2,891 2,441

* Employee population data expressed here may vary from our 10-K form depending on the time of year in which the data was gathered.


** 0 records have values out of bound (e.g., age=0). 575 records do not specify gender.

†† 0 records have values out of bound (e.g., age=0). 407 records do not specify gender.

*** 1 record has values out of bound (e.g., age=0). 72 records do not specify gender.


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EMPLOYEE TURNOVER (VOLUNTARY AND INVOLUNTARY)*†

FY17** FY18†† FY19***

Total employee turnover rate (total employees/# employee turnovers) 15% 16% 15% 24 and under 3,613 3,426 2,652 25-39 40-54 55-69

6,4803,316737

6,9743,268610

7,2253,376659

70+ 26 10 13Voluntary employee turnover rate (total employees/ # voluntary employee turnovers)

12% 13% 12%

Female††† 6,760 7,075 7,159 Asia Pacific 665 750 808 Canada 114 93 98 Europe/Central Asia/Middle East/Africa 1,051 888 1,094 Latin America 3,058 3,615 3,188 U.S. and Puerto Rico 1,872 1,729 1,971

* Turnover calculated with Average Headcount for the FY. Employee population data expressed here may vary from our 10-K form depending on the time of year in which the data was gathered.


** 0 records have values out of bound (e.g., age=0). 699 records do not specify gender.

†† 0 records have values out of bound (e.g., age=0). 204 records do not specify gender.

*** 1 record has values out of bound (e.g., age=0). 91 records do not specify gender.


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U.S. EMPLOYEE DEMOGRAPHICS*†

FY17 FY18 FY19

American Indian or Alaska Native 148 145 138

Asian 5,649 5,616 5,504

Black or African American 3,102 2,680 2,206

Hispanic or Latino 3,181 3,173 3,101

Native Hawaiian or Other Pacific Islander 152 145 140

White 25,277 23,820 21,965

Two or More Races 596 667 710

Unspecified** 12,158 13,521 15,829

* Calculated as Average Headcount for the FY. United States only, excluding Puerto Rico.


**Includes records coded as Do Not Want to Disclose or Blank

UC202004824a EN © 2020 Medtronic. Minneapolis, MN. All Rights Reserved. Printed in USA. 4/2020