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2023 SASB Index

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Our Sustainability Accounting Standards Board (SASB) Index discloses information in alignment with SASB’s Health Care Delivery and Medical Equipment & Supplies standards. This is part of our commitment to provide transparent and relevant information on our economic, environmental- and social performance to our stakeholders. Going forward, we will continuously strive further to improve our disclosure of quantitative metrics and further to enhance our SASB reporting.

Some of the information requested relates to United States requirements. For this reason, answers provided to these questions are limited to our business in the United States. In other regions, we are also subject to health care products and services standards in line with local laws and regulations.

SASB Code Accounting Metric Response / Sources

Health Care Delivery

Energy Management
HC-DY-130a.1 (1) Total energy consumed, (2) percentage grid electricity, (3) percentage renewable

(1) 9,183,243 GJ (2.6 million MWh)
(2) 50%
(3) 10%

For further information on energy management, see our Non-Financial Group Report – Energy and climate protection (pages 116 ff.).

Waste Management
HC-DY-150a.1 Total amount of medical waste, percentage (a) incinerated, (b) recycled or treated, and (c) landfilled

Total Waste: 183,050 metric tons 

Hazardous Waste: 53,154 metric tons 

Non-Hazardous: 129,896 metric tons 

For further information on our waste management activities, see our Non-Financial Group Report – Waste management (page 119 f.).

Note: Our calculation of waste generation is based on data collected from our production sites and in-center dialysis clinic business. Calculations include estimations and extrapolations. 

HC-DY-150a.2 Total amount of: (1) hazardous and (2) nonhazardous pharmaceutical waste, percentage (a) incinerated, (b) recycled or treated, and (c) landfilled
Patient Privacy & Electronic Health Records
HC-DY-230a.2 Description of policies and practices to secure customers’ protected health information (PHI) records and other personally identifiable information (PII)

FME processes patients’ information in accordance with its Global Privacy Principles.  For a description of policies and practices related to securing our patients’ health information and further data, see our Non-Financial Group Report – Protecting data (pages 113 ff.).  Also see our FMC NA Notice of Privacy Practices for a description of how medical information is used and disclosed in the United States.

HC-DY-230a.3 (1) Number of data breaches, (2) percentage involving (a) personally identifiable information (PII) only and (b) protected health information (PHI), (3) number of customers affected in each category, (a) PII only and (b) PHI In 2023, Fresenius Medical Care identified 50 data breaches in the U.S. business, as defined by applicable state and federal law. These breaches affected PHI (Personal Health Information) and one of these also impacted PII (Personal Identifiable Information).
HC-DY-230a.4 Total amount of monetary losses as a result of legal proceedings associated with data security and privacy

Fresenius Medical Care did not incur monetary losses in the United States during the reporting period as a result of legal proceedings associated with data security and privacy, (meaning any adjudicative proceedings before a court, regulator, arbitrator or otherwise).

All relevant legal proceedings and related financial effects are disclosed in our Annual Report – Notes to the Consolidated Financial Statements (pages 290 f.).

Access for Low-Income Patients
HC-DY-240a.1 Discussion of strategy to manage the mix of patient insurance status In our dialysis clinics, we treat patients with all kinds of insurance status. In the United States, the insurance mix includes the federal health insurance programs Medicare and Medicaid, as well as private/alternative payors such as commercial insurance and private funds. For information on our efforts to expand access to high-quality care for more patients, see our Non-Financial Group Report –  Access to health care (pages 102 f.).
Quality of Care & Patient Satisfaction
HC-DY-250a.2 Number of Serious Reportable Events (SREs) as defined by the National Quality Forum (NQF) We do not report this data. For information on quality of care and patient satisfaction, see our Non-Financial Group Report – Quality of care (pages 101 f.).
HC-DY-250a.3 Hospital-Acquired Condition (HAC) Score per hospital We do not operate acute care hospitals in the United States. Consequently, this indicator is not relevant for us.
HC-DY-250a.5 Number of (1) unplanned and (2) total readmissions per hospital We do not report this data. For information on quality of care and patient satisfaction, see our Non-Financial Group Report – Quality of care (pages 101 f.).
Management of Controlled Substances
HC-DY-260a.1 Description of policies and practices to manage the number of prescriptions issued for controlled substances

The United States dialysis services business does not permit controlled substances to be kept or administered in its outpatient dialysis units.  Dialysis facility staff do not prescribe controlled substances. 

Fresenius Rx (located in the US) does not supply controlled substances.

Azura Vascular Care (located in the US) has policies and procedures consistent with all Controlled Substance Regulations found within the Center for Medicare and Medicaid Services (CMS), the Drug Enforcement Administration (DEA)- and Accrediting Bodies. Azura’s internal and external medication management programs are comprehensive in terms of efficiency, meeting regulatory requirements- and keeping patients safe. Azura partners with a pharmacy consulting company to ensure compliant medication management. 

In the dialysis services business in other parts of the world where controlled substances are permitted, we have established specific protocols to ensure the safe handling and storage of these medications. In those locations we ensure that the appropriate level staff is trained on the appropriate use, storage- and disposal of controlled substances as required by local/regional laws. Similarly, staff supports patients with substance abuse disorders where required by local/regional laws.

Pricing & Billing Transparency
HC-DY-270a.1 Description of policies or initiatives to ensure that patients are adequately informed about price before undergoing a procedure

The Care Delivery patient facing services business (e.g. Fresenius Kidney Care’s in-center, home dialysis as well as Nephrocare, Fresenius Kidney Care, Cura Hospital Group, Azura Vascular, Fresenius Physician Services, Spectra Labs) follows the local laws and requirements governing pricing disclosures. The method of communication varies by country and includes written communication, website posting- and in-person consultation, as required.

We work with the insurer/payor to understand the patient’s payment responsibility. For self-pay, we work directly with the patient to provide estimates of what they will be responsible for.

The US Care Delivery patient facing services business (e.g. Fresenius Kidney Care’s in-center, home dialysis as well as Azura Vascular, Fresenius Physician Services, Spectra Labs) has two approaches. For insured patients, the business first submits a claim to the insurance provider. The insurance provider informs the business about what the patient is responsible for based on their plan. In the case of self-pay patients, the business can provide an estimate of costs. 

For the patient-facing services business outside of the United States (e.g. Nephrocare, Fresenius Kidney Care, Cura Hospital Group), the company follows the pricing requirements outlined by the national health system in that country.
HC-DY-270a.2 Discussion of how pricing information for services is made publicly available

The US Care Delivery patient facing services business (e.g., Fresenius Kidney Care’s in-center, home dialysis as well as Azura Vascular, Spectra Labs), the Company sets our pricing and certain pricing information is made publicly available where required by price transparency laws. 

For the patient-facing services business outside of the United States (e.g. Nephrocare, Fresenius Kidney Care, Cura Hospital Group), pricing for services is usually subject to local law and reimbursements. 

For more information on reimbursements, see our form 20-F.
HC-DY-270a.3 Number of the entity’s 25 most common services for which pricing information is publicly available, percentage of total services performed (by volume) that these represent
Employee Health & Safety
HC-DY-320a.1 Total recordable incident rate (TRIR) for (a) direct employees and (b) contract employees

For the total recordable incident rate, see our ESG Performance Data – Occupational health and safety (page 10).

Employee Recruitment, Development & Retention
HC-DY-330a.1 (1) Voluntary and (2) involuntary turnover rate for: (a) physicians, (b) non-physician health care practitioners, and (c) all other employees

For 2023, our total voluntary turnover rate is 16.9%, and our total involuntary turnover rate is 4.9%. The global* voluntary turnover rate for physicians is 15.1% and the involuntary turnover rate is 7.6%. For non-physician health care practitioners, the voluntary turnover rate is 20.9% and the involuntary turnover rate is 8.8%. For further information on voluntary and involuntary turnover rates, see our ESG Performance Data – Talent management (pages 8 f.) and our Non-Financial Group Report – Employees worldwide (pages 109 f.).

*Excludes Cura, Fuji and ERS joint ventures

HC-DY-330a.2 Description of talent recruitment and retention efforts for health care practitioners

For information on recruitment and retention efforts, see our Non-Financial Group Report – Attracting and developing talent (page 100), our global career website, and our employee website.

For information on nurses training programs, global career paths, and insights into the jobs of our clinical staff, see our Nephrocare website, our corporate website, and our career website in the United States.

Climate Change Impacts on Human Health & Infrastructure
HC-DY-450a.1 Description of policies and practices to address: (1) the physical risks due to an increased frequency and intensity of extreme weather events and (2) changes in the morbidity and mortality rates of illnesses and diseases, associated with climate change and (3)
emergency preparedness and response

We have dialysis clinics in many regions of the world with diverse geographic, social- and economic conditions, serving a vulnerable population of patients who need regular dialysis treatment multiple times a week. To allow us to continue treating our patients in extreme conditions, we have developed an emergency response system comprising regional disaster response teams. For further information on our disaster response activities, see our Risk and Opportunities Report – Unpredictable events (page 82) and our Non-Financial Group Report – Crisis and emergency response (pages 104 f.). Additionally, take a look at the disaster relief fact sheet and our website communication on disaster response in emergencies. 

To evaluate the impact of physical and transition risks on our business model in connection with climate change, we initiated a physical climate scenario analysis. We plan to continue conducting a transition risk assessment in 2024 to evaluate risks related to our management of the transition to renewable energy and climate neutrality (Non-Financial Report 2023 p. 116 f.). 

Fraud & Unnecessary Procedures
HC-DY-510a.1 Total amount of monetary losses as a result of legal proceedings associated with Medicare and Medicaid fraud under the False Claims Act The United States business did not sustain any monetary losses as a result of such proceedings during the reporting period.

Medical Equipment and Supplies

Affordability & Pricing
HC-MS-240a.2 Description of how price information for each product is disclosed to customers or to their agents The business makes certain pricing information publicly available where required by price transparency laws. Pricing is usually subject to local law and reimbursements.
HC-MS-240a.3 Percentage change in: (1) weighted average list price and (2) weighted average net price across product portfolio compared to previous reporting period
Product Safety
HC-MS-250a.1 (1) Number of recalls issued, (2) total units recalled In the United States, there were seven recalls of drugs and devices in 2023 in the form of removals, corrections- or alerts. In non-U.S. markets, there were three recalls of medical devices and no recalls of medicinal products in 2023. Products of Fresenius Medical Care Nephrologica Deutschland GmbH are not in scope.
HC-MS-250a.2 List of products listed in the FDA’s MedWatch Safety Alerts for Human Medical Products database We do not report this data. For information on product safety and quality, see our Non-Financial Group Report – Product stewardship (pages 106 f.).
HC-MS-250a.3 Number of fatalities associated with products

No fatalities have been reported in which a causal relationship with our products has been definitively established.

HC-MS-250a.4 Number of enforcement actions taken in response to violations of good manufacturing practices (GMP) or equivalent standards, by type In 2023, one warning letter was issued by the FDA to Fresenius Medical Care North America located at Waltham, MA 02451-1521. Corrective measures were initiated and are implemented in response to the warning letter.
Ethical Marketing
HC-MS-270a.1 Total amount of monetary losses as a result of legal proceedings associated with false marketing claims All relevant legal proceedings and related financial effects are disclosed in our Annual Report – Notes to the consolidated financial statements (pages 290 ff.). None of such legal proceedings was associated with false marketing claims which resulted in monetary losses.
HC-MS-270a.2 Description of code of ethics governing promotion of off-label use of products Our Code of Ethics and Business Conduct outlines our commitment to always be truthful, accurate, and not misleading when promoting our products and services. For further information on advertising and promotion, see our Code of Ethics and Business Conduct – Advertising and promotion (page 22).
Product Design & Lifecycle 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

It is essential that our products and services are effective and reliable, and that they pose as little risk as possible to patients. Our standards for planning, conducting- and monitoring clinical studies help us enhance the quality and safety of our products. For further information on the safety of our products, see our Non-Financial Group Report – Product stewardship (pages 106 f.).

To help us understand the environmental impact of our products, we conduct simplified product life-cycle assessments for selected products. These assessments identify the life-cycle phase with the highest impact and the processes and materials we need to focus on in order to improve the eco-performance of our products and services.

In 2023, we launched a Portfolio Sustainability Assessment to further evaluate the sustainability performance of our products and services. The assessment aims to provide greater transparency of our portfolio's sustainability taking into account social, environmental- and economic contributions. It creates a basis for strategic portfolio decisions that systematically consider our sustainability impact. For further information on our Portfolio Sustainability Assessment, see our Non-Financial Group Report – Portfolio Sustainability Assessment (page 105).

HC-MS-410a.2 Total amount of products accepted for take-back and reused, recycled, or donated, broken down by: (1) devices and equipment and (2) supplies

We donate funds, dialysis machines, and medical supplies to organizations that require support. In our global survey on corporate citizenship activities, it was reported that we donated around 4.7 metric tons of devices and equipment reflecting a total value of around 151,800 €. We also donated 52 metric tons of supplies reflecting a total value of around 376,000 €. Our activities include donated devices, equipment, and supplies with a monetary value of more than 508,000 € to support patients and employees in Ukraine, Turkey, Sudan, Morocco, and Egypt.

For further information on waste reduction initiatives, see our Non-Financial Group Report – Waste management (pages 119 f.).

(1) Equipment & Product (Disaster Relief: Ukraine, Turkey, Sudan, Morocco and Egypt): 508,962.74 € / Total Weight: 51.70370 metric tons

(2) Total Equipment: 151,793.74 € / Equipment Weight: 4.74460 metric tons

Total Product/Supplies: 376,491.11 € / Product Weight: 51.92422 metric tons

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 Not applicable.
HC-MS-430a.2 Description of efforts to maintain traceability within the distribution chain We are analyzing the environmental and social impact associated with our supply chain. For further information on our supply chain management, see our Non-Financial Group Report – Supplier management (pages 125 f.).
HC-MS-430a.3 Description of the management of risks associated with the use of critical materials

Sourcing of mineral raw materials is an important aspect of our commitment to sustainable procurement.

We are subject to the provisions of Section 1502 of the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) relating to conflict minerals. As outlined in our Conflict Minerals Policy, we adopt standards in line with the Organization for Economic Co-operation and Development’s (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

We are committed to compliance with Section 1502 of the Dodd-Frank Act and encourage our suppliers to foster similar commitments of their supply chain related to conflict minerals disclosures. Suppliers who are non-compliant with our Conflict Minerals Policy are reviewed for continued business.

For additional information on this topic, see our corporate supply chain website. On this website, you find a statement on responsible minerals sourcing as well as our annual Conflict Minerals Report.

Business Ethics
HC-MS-510a.1 Total amount of monetary losses as a result of legal proceedings associated with bribery or corruption We did not have monetary losses associated with formal legal proceedings associated with bribery or corruption in 2022. All relevant legal proceedings and related financial effects are disclosed in our Annual Report – Notes to the consolidated financial statements (pages 216 ff.).
 
HC-MS-510a.2 Description of code of ethics governing interactions with health care professionals

We have a Code of Ethics and Business Conduct that covers general compliance concepts and standards, including the expectation that all employees perform their duties in accordance with the Company’s purpose, global values, policy, the Code of Ethics and Business Conduct, and the law. The general principles in the Code of Ethics and Business Conduct are supported by policies that address specific situations in accordance with all applicable local laws, including interactions with health care professionals.

Our global compliance program helps us operate our business in accordance with the law and provides mandatory internal guidelines for our employees. The program is based on our Code of Ethics and Business Conduct, a binding framework that governs how our employees interact with patients, colleagues, business partners, government officials and other stakeholders. The Code covers topics that are relevant for our business, such as patient care, product and service quality, anti-corruption and anti-bribery, health and safety, data privacy, supplier selection, non-retaliation of whistle-blowers and human rights.