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2022 GRI Index

Fresenius Medical Care has reported the information cited in this Global Reporting Initiative (GRI) content index for the period from 1 January 2022 to 31 December 2022 with reference to the GRI Standards. This disclosure is part of our commitment to provide transparent and relevant information on our economic, environmental, and social performance to our stakeholders.
GRI 1 used: GRI 1: Foundation 2021

GRI Standard Link Comment
The organization and its reporting practices
2‑1 Organizational details Imprint and contact
Notes to consolidated financial statements: The Company
Regional organization
 
2-2 Entities included in the organization’s sustainability reporting Non-Financial Group Report: About this report
Notes to consolidated financial statements: Principal subsidiaries
 
2-3 Reporting period, frequency and contact point Contact The reporting period is from January 1 to December 31, 2022. In compliance with German Commercial Law, we apply a yearly reporting cycle. Our most recent combined Annual and Non-Financial Group Report 2022 was published on March 23, 2023.
2-4 Restatements of information Employees: Employee overview
Declaration on Corporate Governance: Gender diversity and targets
 
2-5 External assurance Report by the Supervisory Board: Separate Non-Financial Group Report
Independent practitioner’s report on a limited assurance engagement on non-financial reporting
 
Activities and workers
2-6 Activities, value chain and other business relationships Overview of the Group: Business model
Risks and Opportunities Report: Procurement
Supplier Management
Our suppliers are located in more than 100 countries across the world. As a vertically integrated company, we purchase products and services to produce dialysis machines. This includes 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. We also collaborate with third parties such as distributors to support our downstream activities.
2-7 Employees Employees
ESG Performance Data
 
2-8 Workers who are not employees   So far, we have only been tracking this non-employee population locally. We are working on methods to systematically monitor this group.
Governance
2-9 Governance structure and composition Report by the Supervisory Board: Committees of the Supervisory Board
Declaration on Corporate Governance
Sustainability management: Sustainability governance
 
2-10 Nomination and selection of the highest governance body Declaration on Corporate Governance: The General Partner and its bodies
Declaration on Corporate Governance: Supervisory Board of the Company
Declaration on Corporate Governance: Diversity concept and targets
 
2-11 Chair of the highest governance body Declaration on Corporate Governance: Group management and supervision structure
Declaration on Corporate Governance: The General Partner and its bodies
 
2-12 Role of the highest governance body in overseeing the management of impacts Sustainability management: Sustainability governance
Declaration on Corporate Governance: Lead Independent Director
 
2-13 Delegation of responsibility for managing impacts Sustainability management: Sustainability governance
Risks and Opportunities Report
Responsibility for the management of sustainability topics and impacts is described in the respective chapters of the Non-Financial Group Report.
2-14 Role of the highest governance body in sustainability reporting Sustainability management: Sustainability governance
Report by the Supervisory Board: Separate Non-Financial Group Report
The Non-Financial Group Report is reviewed and approved by our Chief Executive Officer.
2-15 Conflicts of interest Report by the Supervisory Board: Corporate Governance
Declaration on Corporate Governance: Independence
Declaration on Corporate Governance: Legal relationships with members of the Company’s corporate bodies
We have a policy on conflicts of interest, reflecting our commitment to minimize them. A conflict of interest is any situation/engagement (activity/relationship) that may (potentially) create a conflict to the legitimate interests of FME; or can be perceived as creating a conflict to the legitimate interest of FME. It may arise when personal interests of an employee (resulting from engagements, activities, situations, relationships, etc.) are in conflict with legitimate interests of FME. Conflicting interests may impact the employee’s objectivity and their ability to perform their employment duties in the best interests of FME. A COI as per this Policy includes actual, potential or perceived Conflicts of Interest. 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.
2-16 Communication of critical concerns Compliance  
2-17 Collective knowledge of the highest governance body Sustainability management: Sustainability governance
Declaration on Corporate Governance: Lead Independent Director
Qualification matrix for the members of the Supervisory Board of the Company
Supervisory Board website: Lead Independent Director and ESG expertise
 
2-18 Evaluation of the performance of the highest governance body Declaration on Corporate Governance: Self-assessments  
2-19 Remuneration policies Compensation Report  
2-20 Process to determine remuneration Compensation Report: Management Board members’ compensation
Compensation Report: Compensation of the members of the Supervisory Board
 
2-21 Annual total compensation ratio Compensation Report: Comparative presentation of the development of the compensation  
Strategy, policies and practices
2-22 Statement on sustainable development strategy Statement of CEO in company magazine: Shaping a sustainable tomorrow
Statement of Lead Independent Director on Supervisory Board website: Lead Independent Director and ESG expertise
 
2-23 Policy commitments Code of Ethics and Business Conduct
Human Rights, Workplace Rights, and Labor and Employment Principles
Group-wide Human Rights Statement
Policies and standards
 
2-24 Embedding policy commitments Sustainability management: Strategy
Code of Ethics and Business Conduct
Human Rights, Workplace Rights, and Labor and Employment Principles
Group-wide Human Rights StatementSupplier Code of Conduct
Approaches to embed policy commitments throughout activities and business relationships are described in the respective chapters of the Non-Financial Group Report.
2-25 Processes to remediate negative impacts Patients: Quality of care
Compliance: Monitoring adherence to standards
Human rights: Managing complaints
Employees: Dialogue with employees and their representatives
 
2-26 Mechanisms for seeking advice and raising concerns Patients: Quality of care
Compliance: Monitoring adherence to standards
Human rights: Managing complaints
Employees: Dialogue with employees and their representatives
Code of Ethics and Business Conduct
 
2-27 Compliance with laws and regulations   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.
2-28 Membership associations Sustainability management: Stakeholder inclusion
Patients: Collaborating to improve health care
Human rights: Stakeholder dialogue
Corporate website: Our partners

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, Business for Social Responsibility (BSR), Econsense, European Renal Association – European Dialysis and Transplant Association, the Global Industrial Relations Network (a network of the International Organisation of Employers), MedTech Europe, National Kidney Foundation, Renal Physicians Association.

Stakeholder engagement
2-29 Approach to stakeholder engagement Sustainability management: Stakeholder inclusion
Sustainability management: Material topics
Patients: Collaborating to improve health care
Patients: Innovation and digitalization
Press release: Fresenius Medical Care takes action to close global health gaps, signs “Zero Health Gaps” Pledge at the World Economic Forum
Employees: Employee engagement
Employees: Dialogue with employees and their representatives
Overview of the Group: Global research and development strategy
 
2‑30 Collective bargaining agreements Employees: Dialogue with employees and their representatives  
GRI Standard Link Comment
3-1 Process to determine material topics Sustainability management: Material topics
Materiality analysis
 
3-2 List of material topics Sustainability management: Material topics
Materiality analysis
 
3‑3 Management of material topics Sustainability management: Material topics
Materiality analysis
 
GRI Standard Link Comment
GRI 201: Economic Performance 2016
201-1 Direct economic value generated and distributed Overview of the Group: Primary Key Performance Indicators
Compensation Report: Comparative presentation of the development of the compensation
Notes to the consolidated financial statements: Personnel expenses
 
201-2 Financial implications and other risks and opportunities due to climate change Risks and Opportunities Report: ESG requirements
Sustainability management: Risk management
Environmental protection: Energy and climate protection
Notes to consolidated financial statements: Impacts of climate change on accounting
 
201-3 Defined benefit plan obligations and other retirement plans Notes to consolidated financial statements: Employee benefit plans  
201-4 Financial assistance received from government Economic Report: COVID-19 relief measures  
GRI 204: Procurement Practices 2016
204-1 Proportion of spending on local suppliers Supplier management The amount spent on local suppliers represents 31% of the total amount spent on the operating segment Care Enablement. Local refers to German suppliers.
GRI 205: Anti-corruption 2016
205-1 Operations assessed for risks related to corruption Risks and Opportunities Report: Corruption and fraud
Compliance

 

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

Compliance training has been provided to employees, governance bodies, and selected third parties. In the reporting year, we assessed and approved around 21,000 third parties.

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

  2022 2021
Overall 118,723 (95%) 100,099 (89%)
Europe, Middle East and Africa 25,523 (93%) 28,079 (89%)
North America 73,695 (96%) 57,716 (94%)
Asia-Pacific 8,339 (94%) 7,138 (91%)
Latin America 11,166 (95%) 7,166 (63%)
205-3 Confirmed incidents of corruption and actions taken Compliance
Notes to the consolidated financial statements: Commitments and contingencies
Form 20-F
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.
GRI 207: Tax 2019
207-1 Approach to tax Group Tax Policy

As a global provider of products and services for people with kidney diseases, we are active in more than 100 countries. Due to our business activities, we are subject to various local tax obligations. In the countries in which we operate, we not only support the development of health care systems, but also create jobs that contribute to local tax revenue. This enables us to make a significant contribution to preserving the macroeconomic stability of national economies.

The basis for paying taxes is the business activities of Fresenius Medical Care in a country. When choosing a location, many other aspects such as the availability of qualified personnel, or political, economic, legal, and regulatory framework conditions play a role in addition to strategic business issues. In the course of an overall assessment, the possibility of minimizing currency risks as well as tax considerations can also influence the choice of location.

The global distribution of business activities results in transactions between the individual companies of the Fresenius Medical Care Group worldwide. The pricing of these intercompany transactions is based on the internationally recognized arm's length principle and is in line with the OECD transfer pricing guidelines and the respective local transfer pricing rules. This ensures that profits are generated and taxed where value is created. The intercompany transactions are documented on the basis of legal requirements in accordance with the applicable OECD guidelines and are disclosed to tax authorities upon request.

207-2 Tax governance, control, and risk management Group Tax Policy

We have implemented risk management systems that also cover tax risks. In 2022, we mandated an independent external tax auditor to review our Tax Compliance Management System (Tax CMS) in Germany based on an auditing standard (IDW PS 980) and OECD standards. The audit report confirmed that we appropriately mitigate tax-related risks.

207-3 Stakeholder engagement and management of concerns related to tax Group Tax Policy
Compliance

Fresenius Medical Care does not specifically settle in certain countries in order merely to generate tax benefits or create tax structures – the focus is always on our business activities.

Information on ways to report suspected acts of non-compliance can be found in our separate Non-Financial Group Report.
207‑4 Country-by-country reporting  
Effective tax rate (%) FY 2022 FY 2021 FY 2020
Overall 26.7 22.4 25.9
Europe, Middle East and Africa 37.4 21.1 24.3
thereof Spain 10.8 - -
North America 21.2 21.0 22.7
thereof USA 21.1 - -
Asia-Pacific 35.5 28.7 22.3
thereof China (incl. Hongkong) 46.4 - -
Latin America 120.5 -50.7 -6.3
Additional Material Topic: Innovation and R&D
3-3 Management of material topics Patients: Innovation and digitalization
Patients: Product improvements
Overview of the Group: Research and development
 
GRI Standard Link Comment
GRI 302: Energy 2016
302-1 Energy consumption within the organization Environmental protection: Energy and climate protection
  TJ Million MWh
Energy1 9,324 2.6
Electricity 4,746 1.3
Natural gas 4,349 1.2
Others2 229 <0.1


We use external certifications in addition to our own environmental standards if they add value. In 2022, a total of ten production sites were certified according to ISO 14001 standards. They accounted for 32% of our total energy consumption. In addition, two production sites have ISO 50001 certification. They accounted for 22% of our total energy consumption.

1 In part subject to extrapolations. Including the energy consumption of our production sites and the electricity consumption of in-center treatments in our dialysis clinics.
2 Including fuel oil, diesel, liquid gas, and district heating. Excluding mobile assets.

302-3 Energy intensity Environmental protection: Energy and climate protection
ESG Performance Data
 
302-4 Reduction of energy consumption Environmental protection: Energy and climate protection
Environment website: Environmental initiatives
 
GRI 303: Water and Effluents 2018
303-1 Interactions with water as a shared resource Environmental protection: Water We analyze water withdrawal and wastewater, including use and reuse opportunities. In addition, we conducted a water risk assessment for our production sites and dialysis clinics, which we further integrated into our risk management.
303-2 Management of water discharge related impact   We are currently investigating the water discharge-related impacts of our production and dialysis business.
303-3 Water withdrawal Environmental protection: Water
  Million m3 Million liters
Water withdrawal3 40.5 40,523
Municipal water4 40.1 40,133
Ground water 0.4 390

 

  Million m3 Million liters
Water withdrawal from locations with extremely high water stress5    
Municipal water 2.4 2,444
Ground water

n/a

n/a


3 Including the water consumption of our production sites and in-center treatments in our dialysis clinics.
4 In part subject to extrapolations.
5 Based on the 2021 water stress assessment of our production sites and our dialysis clinics described in the 2022 Non-Financial Group Report.

303-4 Water discharge   We are currently investigating the water discharge-related impacts of our production and dialysis business.
GRI 305: Emissions 2016
305-1 Direct (Scope 1) GHG emissions Environmental protection: Energy and climate protection

CO2 equivalent emissions factors include CO2, CH4, and N2O gases.

We use external certifications in addition to our own environmental standards if they add value. In 2022, 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 42% of our total reported Scope 1 emissions.
305-2 Energy indirect (Scope 2) GHG emissions Environmental protection: Energy and climate protection

CO2 equivalent emissions factors include CO2, CH4, and N2O gases. We use both location-based and market-based methods based on the residual mix that quantify emissions based on emission factors per country.

We use external certifications in addition to our own environmental standards if they add value. In 2022, a total of ten production sites were certified according to ISO 14001 standards. They accounted for 13% of our total reported Scope 2 market-based emissions. In addition, two production sites have ISO 50001 certification. They accounted for 2% of our total Scope 2 market-based emissions.
305-3

Other indirect (Scope 3) GHG emissions

 

To quantify and disclose Scope 3 emissions, we are preparing a 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 Environmental protection: Energy and climate protection
ESG Performance Data
 
305-5 Reduction of GHG emissions Environmental protection: Energy and climate protection
Environment website: Environmental initiatives
 
GRI 306: Waste 2020
306-1 Waste generation and significant waste-related impacts Environmental protection: Waste  
306-2 Management of significant waste-related impacts Environmental protection: Waste  
306-3 Waste Generated Environmental protection: Waste  
306-4 Waste diverted from disposal Environmental protection: Waste  
306-5 Waste diverted from disposal Environmental protection: Waste  
GRI 308: Supplier Environmental Assessment 2016
308-1 New suppliers that were screened using environmental criteria Supplier management We have defined a set of human rights and environmental criteria (“sustainability-related selection criteria”) that support the selection of new suppliers in sourcing processes initiated in our global procurement systems. These criteria are aligned with the guidance set out in the German Supply Chain Due Diligence Law. We plan to train our Procurement organization on the new processes and begin to use these sustainability-related selection criteria in 2023.
308‑2 Negative environmental impacts in the supply chain and actions taken Supplier management We are currently analyzing the environmental and social impact associated with our supply chain.
GRI Standard Link Comment
GRI 401: Employment 2016
401-1 New employee hires and employee turnover Employees: Employees worldwide
ESG Performance Data
 
401-2 Benefits provided to full-time employees that are not provided to temporary or part-time employees Employees: Compensation and benefits

 

401-3 Parental leaves   We offer a minimum paid parental leave in various countries. We have developed a roadmap to help us further advance in this area.
GRI 403: Occupational Health and Safety 2018
403-1 Occupational health and safety management system Employees: Occupational health and safety
Human Rights, Workplace Rights and Labor and Employment Principles

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).

Despite the variation in national legislation, we are working towards company-wide alignment of standards through thorough internal stakeholder engagement processes.
403-2 Hazard identification, risk assessment, and incident investigation Employees: Occupational health and safety

We identify hazards at the dialysis clinics and production sites that we control 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 America region and to local HR or OHS representatives in the other regions. Incident investigation is a locally managed process that covers all employees.

403-3 Occupational health services   Fresenius Medical Care provides several occupational health services based on the legal requirements of the locations in which we operate. Both in dialysis clinics and production sites, these services are managed and overlooked by specifically trained employees at regional, national, and local levels.
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 OHS-related topics to establish concerns and improvement areas. As we work towards centralization of governance, we aim to create a structure that simplifies the connection between employees and management levels to allow easier consultation processes at all levels.
403-5 Worker training on occupational health and safety Employees: Occupational health and safety

Training on occupational health and safety follows national legislation requirements. All employees who are required to undertake training are closely monitored, and completion rates are checked.

In 2022, we have set ourselves the goal to assess the status of training in all relevant locations globally. A long-term goal is to structure a global training framework in the years to come.
403-6 Promotion of worker health Employees: Occupational health and safety
Global career website
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. In North America, the HR department set up a platform aimed at supporting employees during difficult moments. The goal is to offer this initiative globally.
403-7 Prevention and mitigation of occupational health and safety impacts directly linked by business relationships Patients: Product stewardship
Employees: Occupational health and safety
Global Supplier Code of Conduct
 
403-8 Workers covered by an occupational health and safety management system   We comply with local requirements and legislation in all locations where we operate. Thus, we consider the percentage of employees covered by an occupational health and safety management system to be 100%. We have no control over the occupational health and safety management system coverage of contractors and non-direct employees.
403-9 Work-related injuries Employees: Occupational health and safety
ESG Performance Data

We are committed to providing a safe and healthy work environment. We strive to prevent work-related accidents and hazards to protect our employees and contractors. As part of the Global Sustainability Program, we have been working to create a centralized reporting process on recordable and lost time injuries and fatalities. We monitor three KPIs at global level: number of work-related fatalities, total recordable injury frequency rate (TRIFR), and lost time injury frequency rate (LTIFR).

In our dialysis clinics, the most frequently reported type of injuries are minor injuries, such as injuries resulting from needlesticks. To further prevent injuries, each dialysis clinic has introduced measures such as offering training programs at local level.
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. We plan to align the global definition for work-related ill health in 2023 and to begin internal reporting in 2024.
GRI 404: Training and Education 2016
404-1 Average hours of training per year per employee Employees: Attracting and developing talent
ESG Performance Data
 
404-2 Programs for upgrading employee skills and transition assistance programs Employees: Attracting and developing talent  
404-3 Percentage of employees receiving regular performance and career development reviews Employees: Attracting and developing talent Approximately 55-60% of our employees globally received structured performance reviews in 2022. We plan to implement a global performance management platform and related processes in 2023, which will allow for global tracking and reporting. Once this new system has been implemented, we plan to increase the percentage of employees receiving regular performance reviews over time.
GRI 405: Diversity and Equal Opportunity 2016
405-1 Diversity of governance bodies and employees Employees: Diversity, equity, and inclusion
Declaration on Corporate Governance: Diversity concept and targets
ESG Performance Data
 
405-2 Ratio of basic salary and remuneration of women to men Fair pay statement  
GRI 406: Non-discrimination 2016
406-1 Incidents of discrimination and corrective actions taken Compliance: Monitoring adherence to standards
Code of Ethics and Business Conduct
Human rights
Human Rights, Workplace Rights, and Labor and Employment Principles
Non-discrimination topics are integrated into our mandatory Code of Ethics and Business Conduct training. We encourage reporting violations and take complaints about discrimination seriously. When employees, patients, or third parties report violations of our Code of Ethics and Business Conduct and other company policies, we take remedial and corrective action. This includes disciplinary action, personal counseling, awareness raising session for the affected department, training, appropriate feedback to the reporting person, termination of the business relationship.
GRI 407: Freedom of Association and Collective Bargaining 2016
407-1 Operations and suppliers in which the right to freedom of association and collective bargaining may be at risk Employees: Dialogue with employees and their representatives
Supplier management
Global Supplier Code of Conduct
As stated in our Global Social and Labor Standard Policy, we respect our employees’ freedom of association and their right to join or not to join a collective body without fear of reprisal, intimidation, or harassment. 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. In addition, our Global Supplier Code of Conduct outlines our expectations towards our suppliers in this regard.
GRI 408: Child Labor 2016
408-1 Operations and suppliers at significant risk for incidents of child labor Supplier management
Human rights
Code of Ethics and Business Conduct
Global Supplier Code of Conduct

Our commitment to preventing child labor from occurring within both our business and supply chain is defined in several company policies, such as our Code of Ethics and Business Conduct, our Global Social and Labor Standards Policy, and our Global Supplier Code of Conduct.

In 2022, we further developed our procedures for evaluating suppliers based on sustainability risks including child labor. So far, no cases of child labor in our supply chain were reported. Potential cases would be investigated and remedied.
GRI 409: Forced or Compulsory Labor 2016
409-1 Operations and suppliers at significant risk for incidents of forced or compulsory labor Supplier management
Human rights
Code of Ethics and Business Conduct
Global Supplier Code of Conduct

Our commitment to preventing acts of modern slavery and human trafficking from occurring within both our business and supply chain is defined in in several company policies, such as our Code of Ethics and Business Conduct, our Global Social and Labor Standards Policy, and our Global Supplier Code of Conduct.

In 2022, we further developed our procedures for evaluating suppliers based on sustainability risks including forced or compulsory labor. So far, no cases of forced or compulsory labor in our supply chain were reported. Potential cases would be investigated and remedied.

GRI 414: Supplier Social Assessment 2016
414-1 New suppliers that were screened using social criteria Supplier management We have defined a set of human rights and environmental criteria (“sustainability-related selection criteria”) that support the selection of new suppliers in sourcing processes initiated in our global procurement systems. These criteria are aligned with the guidance set out in the German Supply Chain Due Diligence Law. We plan to train our Procurement organization on the new processes and begin to use these sustainability-related selection criteria in 2023.
414-2 Negative social impacts in the supply chain and actions taken Supplier management We are currently analyzing the environmental and social impact associated with our supply chain.
GRI 415: Public Policy 2016
415-1 Political contributions Political Engagement and Advocacy Statement  
GRI 416: Customer Health and Safety 2016
416-1 Assessment of the health and safety impacts of product and service categories Patients: Product stewardship 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
Patients: Product stewardship
Notes to the consolidated financial statements: Commitments and contingencies
Form 20-F
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.
GRI 417: Marketing and Labeling 2016
417-1 Requirements for product and service information and labeling Code of Ethics and Business Conduct  
417-2 Incidents of non-compliance concerning product and service information and labeling   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.
417‑3 Incidents of non-compliance concerning marketing communications   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.
GRI 418: Customer Privacy 2016
418-1 Substantiated complaints concerning breaches of customer privacy and losses of customer data Protecting data
Code of Ethics and Business Conduct
Notice of Privacy Practices

In 2022, the U.S. business identified 54 data breaches, as defined by applicable state and federal law.  These breaches affected PHI (Personal Health Information).  Fresenius Medical Care also reported 1 data breach in Serbia (data breach as defined by applicable law).

In 2022, we engaged an external party to perform a global cybersecurity assessment using the NIST Cyber Security Framework (CSF). NIST CSF is a globally recognized framework to measure and benchmark cybersecurity programs and risks. Our senior leadership, management, and supervisory boards receive cybersecurity updates at least three to four times yearly.

Additional Material Topic: Quality of Care and Patient Satisfaction
3-3 Management of material topics Patients We have set it on our agenda for 2023 to review our targets for grievance handling time and to identify improvements.
Additional Material Topic: Corporate Culture incl. Tone from the Top 
3-3 Management of material topics Compliance: Compliance culture In order to promote 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 2022, we launched four global campaigns to raise awareness about key compliance topics, engage and equip leaders and employees with resources to integrate integrity and compliance into their day to day. We designed and distributed 70 pieces of content, such as videos, articles, and gamified content, to position leadership in the ethics and integrity space. We also enforce tracking processes, e.g., the Integrity Communications Survey, to monitor deployment, awareness, and changes in mindset as we a build a healthy and sustainable organizational culture.