|GRI 103-2||The management approach and its components|| Fresenius Medical Care has a global compliance program in place. It aims to ensure adherence to legal requirements and our internal company guidelines. The program is based on our Code of Ethics and Business Conduct (“Code”), a binding framework that governs how our employees interact with patients, colleagues, business partners, officials and society. The Code covers topics that are relevant for our business – from patient care, quality, anti-corruption and bribery to health and safety, data privacy and environmental protection. It also includes our commitment to respecting material human rights with regard to topics such as working conditions, non-discrimination and grievance mechanisms. The guidelines of our Code of Ethics and Business Conduct are mandatory for the Company’s employees and managers, including members of the Management Board. The Code also applies to the operations of all direct and indirect subsidiaries that are majority-owned or controlled by us in some other way. Our Global Chief Compliance Officer is responsible for managing and enhancing the compliance management system and organization. He reports directly to the CEO and is supported by a global network of more than 150 compliance professionals.|
Prevent, detect and respond
The primary goal of the compliance program is to prevent, detect, and respond to potential misconduct and violations. This is in line with our commitment to operate in compliance with the law. We promote a culture in which compliance is recognized as everyone’s responsibility. A key element in the prevention of compliance violations is our compliance training program. We make compliance training mandatory for employees in all countries and locations where we are legally permitted to do so. In 2019, we conducted a general e-learning class on anti-bribery and anti-corruption as well as more than 20 specialized training courses for specific target groups. We are continuously expanding our training program.
Monitoring adherence to standards
Our compliance program defines standards and procedures including corrective action for failure to follow policies. To identify the risk of compliance violations, we perform systematic assessments as part of our enterprise risk management. Periodic internal audits are another way to identify risks. All employees are encouraged to report potential cases of non-compliance as well as actual or perceived misconduct that violates our Code of Ethics and Business Conduct, other company guidelines or laws. There are several ways in which they can do so: Employees can reach out to their managers or their superiors or to specialists in functions such as Compliance, Legal or Human Resources. We have also set up an external hotline system operated by an independent, certified third-party vendor for our employees and related third parties to report potential violations of laws or company guidelines. Reports can be made confidentially and, if desired, anonymously, where legally permitted. The system is available 24 hours a day and reports can be made in several local languages. In 2019, around 2,800 reports were received and handled by the responsible departments. In North America, our hotline system has multiple uses, not only for reporting compliance concerns, but also for submitting patient care reports and information security reports. Each report is documented and reviewed based on more than 30 allegation categories. The reports received in 2019 related to different areas of our Code of Ethics and Business Conduct, including policy violation, fraud, corruption, handling of company property as well as human rights related issues. We investigate all cases of potential misconduct and take remediation as well as corrective measures on a case-by-case basis. In 2019, this included improving process mechanisms as well as disciplinary actions that also resulted in termination of employment. We track the implementation of mitigating measures and have an anti-retaliation policy in place. We do not tolerate any form of unjustified detrimental action against employees who have made a report based on good faith.