Weiter zum Inhalt

2021 GRI Index

Our Global Reporting Initiative (GRI) Index was prepared in accordance with the GRI Standards: Core option. This disclosure is part of our commitment to provide transparent and relevant information on our economic, environmental, and social performance to our stakeholders. The majority of references within this index refer to our 2021 Annual Report.

GRI Standard Link Page Comment
Organizational Profile  
102-1 Name of the organization

Imprint and contact

295  
102-2 Activities, brands, products, and services Business model 19  
The Company 184
102-3 Location of headquarters Business model 19  
102-4 Location of operations Business model 19  
102-5 Ownership and legal form Shareholder structure 13  
Corporate governance fundamentals 81
102-6 Markets served Business model 19  
Our customers are mostly health insurers and companies 39
102-7 Scale of the organization Business model 19  
Results of operations, financial position, and net assets 45
Employees 96
Consolidated financial statements 176
102-8 Information on employees and other workers Employees 96 The scope of our reporting includes internal employees only. The data has been compiled as part of our regular HR reporting processes.
ESG Performance Data 4
102-9 Supply chain Business model 19 Our suppliers are located in more than 100 countries across the world. As a vertically integrated company, we purchase products and services for the production of our dialysis machines, such as electrical and mechanical components, chemicals, and tubing systems. In addition, we purchase products and services for our clinic business such as clinical equipment and services, disposables and pharmaceuticals. Furthermore, we purchase peripheral products and services such as professional services, travel services, and logistics.
Procurement 70
Supplier Management 104
102-10 Significant changes to the organization and its supply chain Business model 19  
Consolidated financial statements 46
Shareholders’ equity 236
102-11 Precautionary principle or approach Risks and Opportunities Report 62  
Environment 106
102-12 External initiatives Human rights 105  
Global Supplier Code of Conduct  
Code of Ethics and Business Conduct  
102-13 Membership of associations Stakeholder inclusion 89
 

In the reporting period, we were a member of several external organizations. The most important ones include: American Nephrology Nurses Association, Business for Social Responsibility, American Society of Nephrology, APACMed, European Renal Association – European Dialysis and Transplant Association, Global Industrial Relations Network (a network of the International Organisation of Employers), MedTech Europe, National Kidney Foundation, and Renal Physicians Association.

Examples of our collaboration with these groups include joining the newly established working group on sustainable corporate governance of MedTech Europe, a trade association representing the interests of the medical technology industry in Europe, as well as the working group on business and human rights within the German Chemicals Industry association (Verband der Chemischen Industrie e.V.). We also joined the Corporate Social Responsibility working group within the Confederation of German Employers’ Association (Bundesvereinigung der Deutschen Arbeitgeberverbände) and became a member of the sustainability network econsense.

Collaborating to improve health care 93
Human rights 105
Our partners
Strategy  
102-14 Statement from senior decision-maker Interview with Rice Powell 6  
CEO speech Annual General Meeting 2021 6
Ethics and Integrity  
102-16 Values, principles, standards, and norms of behavior Corporate strategy and objectives 22  
Compliance 100
Code of Ethics and Business ConductCorporate culture 6
Governance  
102-18 Governance structure Sustainability governance 87
 
 
Corporate governance 112
Stakeholder Engagement
102-40 List of stakeholder groups Stakeholder inclusion 89  
102-41 Collective bargaining agreements Dialogue with employees and their  representatives 98  
102-42 Identifying and selecting stakeholders Stakeholder inclusion 89  
Material topics 86
102-43 Approach to stakeholder engagement Stakeholder inclusion 89
 
 
Material topics 86
Quality of care 90
Employee engagement 97
Dialogue with employee and their  representatives 98
102-44 Key topics and concerns raised Stakeholder inclusion 89
 
 
Material topics 86
Materiality analysis  
Reporting Practice
102-45 Entities included in the consolidated
financial statements
Principles of consolidation and composition of the group 185  
102-46 Defining report content and topic Boundaries Material topics 86  
Materiality analysis 86
102-47 List of material topics Material topics 86  
Materiality analysis 86
102-48 Restatements of information Employees 96

The percentages of women at first and second management level below the Management Board in 2020 were adapted in the 2021 Non-Financial Report to reflect a new definition of these levels. The figures now include all managers in the respective leadership positions according to our new global job evaluation system. In previous reporting, the definition included all employees that participated in our Long-Term Incentive Plan and reported directly to a Management Board member.

Gender diversity and targets 130
102-49 Changes in reporting Materiality analysis 86 There were no significant changes from previous reporting periods in the list of material topics and topic Boundaries.
102-50 Reporting period About this report 84  
102-51 Date of most recent report     Our most recent combined Annual and Non-Financial Group Report 2021 was published on March 23, 2022.
102-52 Reporting cycle     In compliance with German Commercial Law, we apply a yearly reporting cycle.
102-53 Contact point for questions regarding the report Contact 295  
102-54 Claims of reporting in accordance with the GRI Standards About this report 84  
102-55 GRI content index Fresenius Medical Care GRI Index    
102-56 External assurance Independent practitioner’s report on a limited assurance engagement on non-financial reporting 110  
Economic  
GRI 204: Procurement Practices 2016
103-1 Explanation of the material topic and its Boundary Supplier management 104  
103-2 The management approach and its components Supplier management 104


 

103-3 Evaluation of the management approach Supplier management 104

 

204-1 Proportion of spending on local suppliers Supplier management 104


 

GRI 205: Anti-corruption 2016
103-1 Explanation of the material topic and its Boundary Compliance 100

We define corruption as the misuse of power for private gain, including bribery. Any direct or indirect payment, or promise, offer, or authorization of a payment of anything of value made to corruptly obtain or retain business or an improper advantage, could be considered a bribe. The offer or acceptance of bribes, including facilitation payments, is strictly prohibited.

103-2 The management approach and its components Sustainability management 85

We have a policy on conflicts of interest, reflecting our commitment to minimize them. Conflicts of interest are defined as situations when the personal interests of an employee (including interests and activities of family members and other non-FME persons) influence or appear to influence an employee’s ability to perform his or her professional duties objectively and in the best interests of FME, and/or interfere with or potentially interfere with FME’s reasonable business interests. Potential conflicts of interest are disclosed via a disclosure form, which is part of the policy/standard operating procedure and reflected in training and guidance materials.

We have policies, controls, and procedures in place to guide donation and sponsorship (“educational grants”) processes. Dedicated committees review and approve charitable donations and educational grants based on a set of compliance criteria reflected in the corresponding policy/standard operating procedure.

As members of MedTech Europe and APACMed, we are collectively committed to complying with their anti-corruption standards. 

Compliance

100
Code of Ethics and Business Conduct 14
MedTech Europe
APACMed
103-3 Evaluation of the management approach Compliance 100 Our compliance measures are monitored by the Global Internal Audit department in independent audits.
205-1 Operations assessed for risks related to corruption Corruption and fraud 71

In addition to various other monitoring activities, at Group level all operations are formally assessed at least annually in terms of all kinds of ethics and compliance risks, including bribery and corruption. 

This is done using specific criteria such as locations, associated Corruption Perceptions Index score, activities, and business units.
Compliance 100
205-2 Communication and training about anti-corruption policies and procedures Compliance 100

Our anti-corruption policies and procedures have been communicated to all Management Board and Supervisory Board members, as well as employees. Likewise, training has been provided to employees, governance bodies and high-risk/selected third parties.

Below you will find an overview of employee training numbers per region:

  2021 2020
Overall 100,099 (89%) 106,927 (97%)
Europe, Middle East, and Africa 28,079 (89%) 29,859 (96%)
North America 57,716 (94%) 58,037 (98%)
Asia-Pacific 7,138 (91%) 7,474 (99%)
Latin America 7,166 (63%) 11,557 (98%)


In 2021, more than 200 third parties received compliance training. Third parties refer to our third parties in the sales channel, i.e., distributors, re-sellers, wholesalers, commercial/sales agents, and any other third party involved in the sales of our products that potentially interact with government officials and/or health care professionals for sales of our products.

For all training, completion is tracked, and overdue cases are addressed through, for example, automated reminders and escalation processes. We target a global compliance training completion rate of 90%.

205-3 Confirmed incidents of corruption and actions taken Compliance 100 Legal matters that Fresenius Medical Care deems to be material or noteworthy are described in the annex of our Annual Report and our 20-F.  
Commitments and contingencies 251
Form 20-F  
GRI 207: Tax 2019
103-1 Explanation of the material topic and its Boundary Group Tax Policy      
103-2 The management approach and its components Group Tax Policy    
103-3 Evaluation of the management approach Group Tax Policy    
207-1 Approach to tax Group Tax Policy    
207-2 Tax governance, control, and risk management Group Tax Policy    
Compliance 100  
207-3 Stakeholder engagement and management of concerns related to tax Group Tax Policy    
207-4 Country-by-country reporting    
Effective tax rate (%) FY 2021 FY 2020 FY 2019
Overall 22.4 25.9 21.8
Europe, Middle East, and Africa 21.1 24.3 24.1
North America 21.0 22.7 19.7
Asia-Pacific 28.7 22.3 30.5
Latin America -50.7 -6.3 5.0

 

Additional Material Topic: Innovation and R&D
103-1 Explanation of the material topic and its Boundary Research and development 33  
103-2 The management approach and its components Research and development 33  
Sustainability management 85
103-3 Evaluation of the management approach Research and development 33  
Product improvements 95  
Environmental  
GRI 302: Energy 2016  
103-1 Explanation of the material topic and its Boundary Environment 106  
103-2 The management approach and its components Sustainability management 85
 
 
Environment 106
103-3 Evaluation of the management approach Environment 106 As part of our Global Sustainability Program, we launched our Global Environmental Policy in 2021, which was approved by the Management Board. It provides a framework for environmental management at a global level and will serve as a basis for developing improvement targets. We have also set global climate targets to reduce emissions.
302-1 Energy consumption within the organization Energy and climate protection 107

 

TJ

Million MWh

Energy1

9,403

2.6

Electricity

4,766

1.3

Natural gas

4,401

1.2

Others2 236 <0.1

We use external certifications in addition to our own environmental standards if they add value. In 2021, a total of ten production sites were certified according to ISO 14001 standards. They accounted for 33% of our total energy consumption. In addition, two production sites have ISO 50001 certification. They accounted for 22% of our total energy consumption.
302-3 Energy intensity Energy and climate protection 107  
ESG Performance Data 10
302-4 Reduction of energy consumption

Energy and climate protection

Environmental initiatives
107
GRI 303: Water and Effluents 2018  
103-1 Explanation of the material topic and its Boundary Environment 106  
103-2 The management approach and its components Sustainability management 85  
Environment 106
103-3 Evaluation of the management approach Environment 106 As part of our Global Sustainability Program, we launched our Global Environmental Policy in 2021, which was approved by the Management Board. It provides a framework for environmental management at a global level and will serve as a basis for developing improvement targets. We expanded the scope of our water stress assessment and established a global network of environmental experts.
303-1 Interactions with water as a shared resource Water 107 As part of our Global Sustainability Program, water withdrawal and wastewater, including use and reuse opportunities, are analyzed. In addition, we conducted a water risk assessment for our production sites and dialysis clinics which we further integrated into our risk management.
303-3 Water withdrawal Water 107

 

Million m3

Million liters

Water3

41.4

41,418

Municipal water4

41.0

40,963

Ground water

0.5

455

 

  Million m3 Million liters
Water withdrawal from locations with extremely high water stress5    
Municipal water 2.4 2,386
Ground water n/a n/a
GRI 305: Emissions 2016
103-1 Explanation of the material topic and its Boundary Environment 106  
103-2 The management approach and its components Sustainability management 85
 
 
Environment 106
103-3 Evaluation of the management approach Environment 106 As part of our Global Sustainability Program, we launched our Global Environmental Policy in 2021, which was approved by the Management Board. It provides a framework for environmental management at a global level and will serve as a basis for developing improvement targets. We have also set global climate targets to reduce emissions.
305-1 Direct (Scope 1) GHG emissions Energy and climate protection 107

CO2 equivalent emissions factors include CO2, CH4, and N2O gases. We calculate our Scope 1 greenhouse gas emissions following the methodology of the Greenhouse Gas Protocol, using the UK Department for Environment, Food and Rural Affairs’ (DEFRA’s) latest version, as well as the emission factors of the International Energy Agency for electricity consumption.

We use external certifications in addition to our own environmental standards if they add value. In 2021, a total of ten production sites were certified according to ISO 14001 standards. They accounted for 54% of our total Scope 1 emissions. In addition, two production sites have ISO 50001 certification. They accounted for 43% of our total Scope 1 emissions.
305-2 Energy indirect (Scope 2) GHG emissions Energy and climate protection 107

CO2 equivalent emissions factors include CO2, CH4, and N2O gases. We calculate our Scope 2 greenhouse gas emissions following the methodology of the Greenhouse Gas Protocol, using the UK Department for Environment, Food and Rural Affairs’ (DEFRA’s) latest version, as well as the emission factors of the International Energy Agency for electricity consumption.

We use external certifications in addition to our own environmental standards if they add value. In 2021, a total of ten production sites were certified according to ISO 14001 standards. They accounted for 9% of our total Scope 2 emissions. In addition, two production sites have ISO 50001 certification. They accounted for 1% of our total Scope 2 emissions.

305-3 Other indirect (Scope 3) GHG emissions    

As part of our Global Sustainability Program, we are planning to quantify and disclose Scope 3 emissions. Therefore, we are preparing a comprehensive hotspot analysis considering all categories defined by the Greenhouse Gas protocol.  

As a result of a preliminary internal analysis, we expect Scope 3 emissions from purchased goods and services, upstream and downstream transportation, and waste generated in our operations will be the most significant.
305-4 GHG emissions intensity Energy and climate protection 107  
ESG Performance Data 11
305-5 Reduction of GHG emissions Energy and climate protection 107 As part of the Global Sustainability Program, we initiated various measures with a view to establishing a global environmental management approach. This includes defining global goals. In January 2022, the Management Board approved new climate targets. We plan to be climate neutral by 2040. By 2030, we aim to reduce Scope 1 (direct) and Scope 2 (indirect) emissions by 50% compared with 2020. In addition, we will assess the impact of Scope 3 emissions in the future so that they can be included in our targets. 
Environmental initiatives  
GRI 306: Waste 2020
103-1 Explanation of the material topic and its Boundary Waste 108  
103-2 The management approach and its components Waste 108  
103-3 Evaluation of the management approach Waste 108 As part of our Global Sustainability Program, we launched our Global Environmental Policy in 2021, which was approved by the Management Board. It provides a framework for environmental management at a global level and will serve as a basis for developing improvement targets. In the context of our Global Sustainability Program, we are planning to develop a global approach to consolidating waste data and to defining reduction targets.
306-1 Waste generation and significant waste-related impacts Waste 108 In 2021, we continued to analyze the waste streams of our production sites and dialysis clinics in all regions. Waste is managed on a local and regional level, allowing us to adhere to all applicable laws and regulations.
306-2 Management of significant waste-related impacts Waste 108

We have ongoing waste initiatives to help us reduce our environmental footprint.

In our Global Sustainability Program, we are planning to develop a global approach to consolidating waste data and to defining reduction targets. As part of this, in 2021 we introduced new measures to improve our waste data collection processes at four pilot production sites. We plan to roll these measures out to all sites at the beginning of 2022.

GRI 307: Environmental Compliance 2016
103-1 Explanation of the material topic and its Boundary Environment 106  
103-2 The management approach and its components Sustainability management 85
 
 
Compliance 100
Environmental management 106
Environmental policy  
103-3 Evaluation of the management approach Environment 106 As part of our Global Sustainability Program, we launched our Global Environmental Policy in 2021, which was approved by the Management Board. It provides a framework for environmental management at a global level and will serve as a basis for developing improvement targets. In the context of our Global Sustainability Program, we are planning to develop a global approach to consolidating waste data and to defining reduction targets.
307-1 Non-compliance with environmental laws and regulations Commitments and contingencies 251 Relevant legal proceedings and related financial affects are disclosed in the annex of our Annual Report and our 20-F.
Form 20-F
GRI 308: Supplier Environmental Assessment 2016
103-1 Explanation of the material topic and its Boundary Supplier management 104  
103-2 The management approach and its components Supplier management 104  
103-3 Evaluation of the management approach Supplier management 104  
308-1 New suppliers that were screened using environmental criteria Supplier management 104 We launched an initiative to evaluate suppliers based on sustainability risks, this includes environmental criteria.
308-2 Negative environmental impacts in the supply chain and actions taken Supplier management 104 We will soon have a complete understanding of our impact on the workforce that makes up our supply chain and the possible risks connected with it
Social
GRI 401: Employment 2016
103-1 Explanation of the material topic and its Boundary Employees 96  
103-2 The management approach and its components Sustainability management 85

We have identified five human resources (HR) related sustainability areas to focus on:

  • Employer attractiveness and retention
  • Employee engagement
  • Learning and development
  • Inclusion and diversity
  • Employment standards and HR policies

 

International program teams are working on implementing global management concepts for the above-mentioned areas.

Employees 96
Human Rights, Workplace Rights and Labor and Employment Principles  
103-3 Evaluation of the management approach Employees 96  
ESG Performance Data 4
401-1 New employee hires and employee turnover Employees 96  
ESG Performance Data 8
Corporate employees website  
GRI 403: Occupational Health and Safety 2018
103-1 Explanation of the material topic and its Boundary Occupational health and safety 98  
103-2 The management approach and its components Sustainability management 85  
Occupational health and safety 98
Human Rights, Workplace Rights and Labor and Employment Principles 2
103-3 Evaluation of the management approach Occupational health and safety 98  
403-1 Occupational health and safety management system Occupational health and safety 98

In accordance with legal requirements, we have established occupational health and safety (OHS) management systems in all locations under the direct responsibility of Fresenius Medical Care. The most important regulatory and legal requirements include:

  • Occupational Health and Safety Administration (OSHA) and voluntary health and safety organizations such as the American National Standards Institute (ANSI) and the National Fire Protection Association (NFPA)
  • EU Directive (89/391/EEC) on the introduction of measures to encourage improvements in the safety and health of workers at work
  • Directive 2010/32/EU on the prevention from sharp injuries in the hospital and health care sector for clinics
  • Regulation 1907/2006/EC concerning the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) (e.g., handling and storage, exposure controls, personal protection)
  • Regulation 1272/2008/EC on the classification, labelling, and packaging of substances and mixtures (i.e., general obligations to classify, label, and package).
403-2 Hazard identification, risk assessment, and incident investigation Occupational health and safety 98

Fresenius Medical Care identifies hazards at the dialysis clinics and production sites that it controls directly. Identified hazards are evaluated based on their severity and/or frequency to determine their likelihood of causing harm. Once this step has been taken, appropriate measures to reduce the hazards and any related risks are identified and adopted. As an example of actions taken, regular meetings are carried out at production sites in Europe, Middle East and Africa to share best practices, discuss lessons learned from accidents, and identify significant near misses.

All actions to mitigate hazards are assigned to a specific OHS department in the North American region and to local HR or OHS representatives in the other regions. Incident investigation is a locally managed process that covers all employees.

As part of our Global Sustainability Program, in 2021, we improved our internal and external reporting processes in addition to our global risk assessment procedures.

403-4 Worker participation, consultation, and communication on occupational health and safety Global Occupational Health and Safety Policy   As highlighted in our Global Occupational Health and Safety Policy, we strive to facilitate consultations on OHS matters with employees and contractors, where appropriate. Therefore, we plan and implement consultation sessions with employees and management on the topics related to OHS to establish concerns and improvement areas. In the North America region, annual reviews are carried out through self-assessment audits to check compliance with OSHA regulations.
403-5 Worker training on occupational health and safety Occupational health and safety 98  
403-6 Promotion of worker health Occupational health and safety 98

Depending on the location, we offer a wide range of benefits aimed at promoting employee health. These benefits focus on preventing illness and injury. Offers include fitness and sport activities, as well as nutrition and safety courses. An example is the initiative Health at Work at Fresenius Medical Care’s headquarters, which includes a variety of classes, workshops, and events to help employees stay fit and healthy.

Global career website  
403-7 Prevention and mitigation of occupational health and safety impacts directly linked by business relationships Product safety and quality 94

 

Occupational health and safety 98
Global Supplier Code of Conduct 7
403-9 Work-related injuries Occupational health and safety 98

Quantitative OHS data is currently reported at regional level. As part of the Global Sustainability Program, we have been working to create a centralized reporting process on injuries and fatalities. In 2021, we identified three global KPIs to report on: number of work-related fatalities, total recordable injury frequency rate (TRIFR), and lost time injury frequency rate (LTIFR). In the last three years (2019 – 2021) no fatalities were recorded. We plan to report the TRIFR in 2023.

In our dialysis clinics, the most frequently reported type of injuries are minor injuries, for example injuries that result from needlesticks. To further prevent injuries, each respective clinic has introduced measures such as offering training programs at local level.

ESG Performance Data 9
403-10 Work-related ill health     We currently do not report the number and rates of work-related ill health. For North America, these figures are included as part of the OSHA rates. At present, responsibility for OHS lies at regional level. As part of our Global Sustainability Program, we have established a project for OHS.
GRI 404: Training and Education 2016
103-1 Explanation of the material topic and its Boundary Employees 96  
103-2 The management approach and its components

Sustainability management

85  
Employees 96
Human rights 105
Diversity concept and targets 129
GRI 405: Diversity and Equal Opportunity 2016
103-1 Explanation of the material topic and its Boundary Employees 96  
103-2 The management approach and its components Sustainability management 85
 
 
Employees 96
Human rights 105
Diversity concept and targets 129
Human Rights, Workplace Rights and Labor and Employment Principles 3
Code of Ethics and Business Conduct 11
103-3 Evaluation of the management approach

Sustainability management

85  
Employees 96
Diversity concept and targets 129
405-1 Diversity of governance bodies and employees Inclusion and diversity 97  
Diversity concept and targets 129
ESG Performance Data 4
GRI 406: Non-discrimination 2016
103-1 Explanation of the material topic and its Boundary Employees 96  
Human rights 105  
103-2 The management approach and its components Monitoring adherence to standards 101

Our global commitment to zero tolerance for discrimination and harassment is anchored in our Human Rights, Workplace Rights and Labor and Employment Principles, as well as in our Code of Ethics and Business Conduct. In December 2021, we launched a Global Social and Labor Standard Policy, which is our leading document concerning human rights topics related to our employees. It outlines our global commitment to a discrimination and harassment-free workplace by specifying that we do not tolerate any form of discrimination based on age, ethnic origin/race, color, national origin, citizenship, disability status, gender, gender expression, gender identity, marital status, pregnancy, religion, sex, sexual orientation, and any other criteria as protected by local laws and regulations. This commitment is further specified in our global policy “Prohibition of Discrimination, Harassment, Sexual Harassment and Bullying”. Non-discrimination topics are integrated into our global Code of Ethics and Business Conduct training. We make compliance training mandatory for employees and take appropriate remedial and corrective action when our Code of Ethics and Business Conduct and company policies are violated, including disciplinary action. Where non-employees such as business partners or patients are involved, other measures might be taken, such as counseling, termination of the business relationship, or other.

Code of Ethics and Business Conduct 11
103-3 Evaluation of the management approach Monitoring adherence to standards 101

Various channels are available to employees, patients, and third parties to report potential violation of human rights, laws, or company policies. The person affected by an issue related to discrimination may alert any member of management or human resources, or make use of other channels such as the Compliance Action Line. We are currently working to improve our data collection in order to track globally the cases on discrimination and other human rights issues, independently from the channel used to report them. 

Human rights 105
406-1 Incidents of discrimination and corrective actions taken Human rights 105  
GRI 407: Freedom of Association and Collective Bargaining 2016
103-1 Explanation of the material topic and its Boundary Dialogue with employees and their representatives 98 In addition to our Human Rights, Workplace Rights and Labor and Employment Principles and our Code of Ethics and Business Conduct, since December 2021, respect for freedom of association and collective bargaining is further outlined in our Global Social and Labor Standard Policy, which is our leading document concerning human rights topics related to our employees. In this new policy we confirm that we respect our employees’ freedom of association and right to join or not to join a Collective Body without fear of reprisal, intimidation, or harassment. We also state that, where employees are represented by a collective body, we are committed to establishing a constructive dialogue with their freely chosen representatives and to respond to a bargaining request in good faith, consistent with applicable law.
103-2 The management approach and its components Dialogue with employees and their representatives 98  
103-3 Evaluation of the management approach Dialogue with employees and their representatives 98  
407-1 Operations and suppliers in which the right to freedom of association and collective bargaining may be at risk Dialogue with employees and their representatives 98 Establishing a solid understanding of our company’s actual and potential human rights impact is a crucial element of our approach to human rights due diligence. In 2020, we initiated a global risk assessment to obtain a holistic view of our actual and potential impact on employees, patients, and local communities in the vicinity of our sites. We launched an initiative to evaluate suppliers based on sustainability risks, this includes freedom of association. For our own operations, we have mapped key activities against human rights standards to identify relevant human rights issues. We have also examined our footprint across countries of operations by considering country-specific risk profiles that are made available via an external sustainability risk data provider. By looking at both our headcount and external risk provider data, countries that may be at risk for freedom of association and collective bargaining include Colombia, Ecuador, India, Russia, Philippines, Turkey.
Supplier management 104
GRI 408: Child Labor 2016
103-1 Explanation of the material topic and its Boundary Human rights 105 In addition to our Human Rights, Workplace Rights and Labor and Employment Principles and our Code of Ethics and Business Conduct, since December 2021, the zero tolerance on child labor is further outlined in our Global Social and Labor Standard Policy, which is our leading document concerning human rights topics related to our employees. In this new policy, we clearly state that we prohibit the employment of children under the age of 16. Furthermore, we are committed to respecting and complying with the applicable minimum age for employment. Any work for the purpose of education and in compliance with applicable laws and regulations, for example as interns, trainees, or apprentices, is not considered “employment” for the purpose of this section.
103-2 The management approach and its components Human rights 105  
103-3 Evaluation of the management approach Human rights 105  
408-1 Operations and suppliers at significant risk for incidents of child labor Supplier management 104

We launched an initiative to evaluate suppliers based on sustainability risks, which includes the risk for incidents of child labor.

For our own operations, we have mapped key activities against human rights standards to identify relevant human rights issues, and we have not identified any child labor risk.
GRI 409: Forced or Compulsory Labor 2016
103-1 Explanation of the material topic and its Boundary Human rights 105  
103-2 The management approach and its components Human rights 105  
409-1 Operations and suppliers at significant risk for incidents of forced or compulsory labor Supplier management 104

Establishing a solid understanding of our company’s actual and potential human rights impact is a crucial element of our approach to human rights due diligence. In 2020, we initiated a global risk assessment to obtain a holistic view of our actual and potential impacts on employees, patients, and local communities in the vicinity of our sites.

For our own operations, we have mapped key activities against human rights standards to identify relevant human rights issues. After careful review and interviews with relevant HR, Legal, and Compliance representatives, we have concluded that the risk of child labor is minimal and that for the moment it does not require additional revision. This risk will be reviewed and updated annually.

For our suppliers, we are will soon have a complete understanding of our impact on the workforce that makes up our supply chain and the possible risks connected with it.

GRI 412: Human Rights Assessment 2016
103-1 Explanation of the material topic and its Boundary Human rights 105  
103-2 The management approach and its components Human rights 105

 

103-3 Evaluation of the management approach Human rights 105  
412-1 Evaluation of the management approach Human rights 105  
412-2 Employee training on human rights policies or procedures Supplier management 104  
Human rights 105  
GRI 414: Supplier Social Assessment 2016
103-1 Explanation of the material topic and its Boundary Supplier management 104  
103-2 The management approach and its components Supplier management 104  
103-3 Evaluation of the management approach Supplier management 104  
414-1 New suppliers that were screened using social criteria Supplier management 104 We launched an initiative to evaluate suppliers based on sustainability risks, including social criteria.
414-2 Negative social impacts in the supply chain and actions taken Supplier management 104 We soon have a complete understanding of our impact on the workforce that makes up our supply chain and the possible risks connected with it.
GRI 416: Customer Health and Safety 2016
103-1 Explanation of the material topic and its Boundary Product safety and quality 94  
103-2 The management approach and its components Sustainability management 85
 
 
Product safety and quality 94
Sector-specific risks 65
103-3 Evaluation of the management approach Product safety and quality 94  
Sector-specific risks 65
416-1 Assessment of the health and safety impacts of product and service categories Product safety and quality 94 For all our medical devices, in-vitro diagnostics, and pharmaceuticals, we assess and manage the risks to and impact on the health and safety of our patients. For these products, we assess 100% of our significant product categories. This risk and impact assessment is performed according to international standards such as ISO 14971 and ICH Q9.
416-2 Incidents of non-compliance concerning the health and safety impacts of products and services Risks and opportunities report 62

 
Legal matters that Fresenius Medical Care currently deems to be material or noteworthy are described in the annex of our Annual Report and our 20-F.
Product safety and quality 94
Commitments and contingencies 251
Form 20-F  
GRI 418: Customer Privacy 2016
103-1 Explanation of the material topic and its Boundary Data protection and cybersecurity 102  
103-2 The management approach and its components Sustainability management 85
 
 
Data protection and cybersecurity 102
Code of Ethics and Business Conduct 18
Notice of Privacy Practices  
103-3 Evaluation of the management approach Data protection and cybersecurity 102  
418-1 Substantiated complaints concerning breaches of customer privacy and losses of customer data     In 2021, the U.S. business identified three data breaches as defined by applicable state and federal law. These breaches affected PHI. Fresenius Medical Care also reported two data breaches in Canada as defined by applicable law.
GRI 419: Socioeconomic Compliance 2016
103-1 Explanation of the material topic and its Boundary Compliance 100  
103-2 The management approach and its components Sustainability management 85

 

We are further developing our global compliance program with the support of the Independent Compliance Monitor (“Monitor”). We continue to improve the Company’s culture regarding compliance, with the support of messages from top management and from middle managers to their teams. We have enhanced this area through regular, company-wide management communications on the topic of compliance, coupled with specific training on compliance communications for our managers.

We have also stepped-up coordination between functions such as Compliance, Finance, Legal, HR and leadership. For instance, we implemented a Global Compliance Oversight Committee at CEO level that meets regularly to evaluate the enhancements and challenges of our anti-corruption program. We established a Project Management Office, staffed by an executive level professional, with responsibility for coordinating collaboration between management and all support functions. We are continually working on our  policies and procedures to make them more user-friendly and to improve their effectiveness.

We are dedicating resources to implementing our third-party due diligence program. This includes expanding our mergers and acquisitions (M&A) due diligence with the aim of establishing a clear understanding of any additional risk the Company might be taking on through its M&A program. We have also implemented a global platform for classifications, due diligence, tracking, and payments related to third-party relationships.

Our financial controls framework builds on an infrastructure with more than 150  internal controls. We work to  continuously strengthen this framework. In 2021, we established a monitoring solution that will help us to identify red flags in instances where questionable transactions are detected.

We also continue to emphasize the importance of internal reporting and investigations. Our Global Investigations department evaluates and examines matters in coordination with the Global Legal function. Cases, statistics, and trends are presented in quarterly meetings of the Global Investigations Oversight Committee, whose members include the Chief Executive Officer, Chief Financial Officer, Global General Counsel, and Global Chief Compliance Officer. Our Global Legal function has increased its capacity to conduct significant internal investigations, for example, through the addition of a dedicated investigations counsel and forensic capabilities, as well as a document management and review platform.

Finally, we have put consistent policies and protocols in place for handling and executing enforcement and discipline decisions. Our Human Resources and Legal departments have set up global and regional disciplinary committees comprised of senior managers, who discuss facts and findings from investigations or circumstances concerning employee discipline. This disciplinary framework fosters a culture in which substantiated violations result in clear, consistent, and appropriate disciplinary action.

Furthermore, we have expanded the Global Internal Audit’s capabilities by adding resources and focusing internal audits in high-risk areas on anti-corruption.

Compliance 100
103-3 Evaluation of the management approach Compliance 100
419-1 Non-compliance with laws and regulations in the social and economic area Risks and Opportunities report 62 Risks from litigation and legal proceedings are reported in our risks and opportunities report. Legal matters that Fresenius Medical Care deems to be material or noteworthy are described in the annex of our Annual Report and our 20-F.
Commitments and contingencies 251
Form 20-F  
Additional Material Topic: Quality of Care and Patient Satisfaction
103-1 Explanation of the material topic and its Boundary Patients 90  
103-2 The management approach and its components Sustainability management 85
 
In our efforts to continuously improve our patient experience, we provide patients and their representatives with different feedback channels. They can use these to make any suggestions or raise concerns, anonymously if they wish. We are committed to resolving any issues in a timely manner and globally target an average handling time of no longer than 15 days.
Patients 90
103-3 Evaluation of the management approach Patients 90  
Additional Material Topic: Corporate Culture incl. Tone from the Top
103-1 Explanation of the material topic and its Boundary Compliance 100  
103-2 The management approach and its components Interview with Rice Powell 6
 
 
Corporate strategy and objectives 22
Sustainability management
85
CEO speech Annual General Meeting 2021 6
Code of Ethics and Business Conduct 4
Corporate culture  
103-3 Evaluation of the management approach Compliance 100

With the objective of promoting a culture of ethical business conduct worldwide, we have developed consistent compliance messaging that we distribute globally so that we speak in one voice. In 2021, we launched four global campaigns, more than 60 pieces of content positioning leadership in the ethics and integrity space, and extensive tracking processes to monitor deployment, awareness, and changes in mindset as we a build a healthy, sustainable organizational culture.

In part subject to extrapolations. Including the energy consumption of our production sites and the electricity consumption of in-center treatments in our dialysis centers.

Including fuel oil, diesel, liquid gas, and district heating. Excluding mobile assets.​​​​​​​

3 Including the water consumption of our production sites and in-center treatments in our dialysis clinics.

In part subject to extrapolations.

5 Based on water stress assessment of our production sites and our dialysis clinics described in the 2021 Non-Financial Report.