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2020 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 2020 Annual Report.

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

Imprint and contact

262  
102-2 Activities, brands, products, and services Business model 19  
The Company 154
102-3 Location of headquarters Business model 19  
102-4 Location of operations Business model 19  
102-5 Ownership and legal form Shareholder structure 14  
Corporate governance fundamentals 78
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 88
Consolidated financial statements 147
102-8 Information on employees and other workers Employees 88 The scope of our reporting includes internal employees only. The data have 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 69
Sustainability in the supply chain 83
102-10 Significant changes to the organization and its supply chain Business model 19  
Consolidated financial statements 46
Shareholders’ equity 204
102-11 Precautionary principle or approach Risks and opportunities report 62  
Environmental protection 97
102-12 External initiatives Human rights 96  
Global Supplier Code of Conduct  
Code of Ethics and Business Conduct  
102-13 Membership of associations Stakeholder inclusion 82
 
In the reporting period, we were a member of several external organizations. The most important ones include: American Nephrology Nurses Association, American Society of Nephrology, APACMed, European Renal Association – European Dialysis and Transplant Association, Global Industrial Relations Network, International Labour Organization’s Corporate Social Responsibility working group, International Organization of Employers, MedTech Europe, Renal Physicians Association.
Collaborating to improve health care 86
Our partners  
Strategy  
102-14 Statement from senior decision-maker Our Global Sustainability Program 8  
CEO speech Annual General Meeting 2020 9
Ethics and Integrity  
102-16 Values, principles, standards, and norms of behavior Corporate strategy and objectives 22  
Promoting integrity 93
Code of Ethics and Business ConductCorporate culture 6
Governance  
102-18 Governance structure Sustainability governance 82
 
 
Corporate governance 102
Stakeholder Engagement
102-40 List of stakeholder groups Stakeholder inclusion 82  
102-41 Collective bargaining agreements Dialog with employee representatives 90  
102-42 Identifying and selecting stakeholders Stakeholder inclusion 82  
Material topics 82
102-43 Approach to stakeholder engagement Stakeholder inclusion 82
 
 
Material topics 82
Improving quality of care 84
Employee engagement 89
Dialog with employee representatives 90
102-44 Key topics and concerns raised Stakeholder inclusion 82
 
 
Material topics 82
Materiality analysis  
Reporting Practice
102-45 Entities included in the consolidated
financial statements
Principles of consolidation and composition of the group 156  
102-46 Defining report content and topic Boundaries Material topics 82  
Materiality analysis 86
102-47 List of material topics Material topics 82  
Materiality analysis 86
102-48 Restatements of information     No restatements of information must be given with regard to the previous Non-Financial Report.
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 Non-Financial Group Report 81  
102-51 Date of most recent report     Our most recent combined Annual and Non-Financial Report 2020 was published on March 23, 2021.
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 262  
102-54 Claims of reporting in accordance with the GRI Standards About this Non-Financial Group Report 81  
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 100  
Economic  
GRI 205: Anti-corruption 2016  
103-1 Explanation of the material topic and its Boundary Compliance 93  
103-2 The management approach and its components Sustainability management 81

We have a policy on conflicts of interests. The disclosure of potential conflicts of interests takes place via a disclosure form and is next to the policy/standard operating procedure, 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 comply with their anti-corruption standards.

Compliance 93
Code of Ethics and Business Conduct 14
MedTech Europe APACMed  
103-3 Evaluation of the management approach Compliance 93

Our compliance measures are monitored by the Global Internal Audit department in independent audits. We have expanded the Global Internal Audit capability by adding resources and focusing internal audits in high-risk areas on anti-corruption. Accordingly, we conducted three anti-corruption-related audits of business partners in 2020 and plan to perform another 20 in 2021.

205-1 Operations assessed for risks related to corruption Corruption and fraud 70

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

This is done using specific criteria such as locations, associated Corruption Perceptions Index score, activities, and business units.

Compliance 93
205-2 Communication and training about anti-corruption policies and procedures Compliance 93 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. We are planning to report on global data for business partner training as well as on further training figures within the next two years. In 2020, we enrolled over 113,000 employees worldwide in Code of Ethics and Business Conduct trainings. Training completion is tracked, and overdue cases are addressed through automated reminders and escalation processes
205-3 Confirmed incidents of corruption and actions taken Compliance 93 Legal matters that Fresenius Medical Care currently deems to be material or noteworthy are described in the annex of our Annual Report.
Commitments and contingencies 217
Additional Material Topic: Innovation and R&D
103-1 Explanation of the material topic and its Boundary Research and development 34  
103-2 The management approach and its components Research and development 34  
Sustainability management 81
103-3 Evaluation of the management approach Research and development 34  
Product improvements 88  
Environmental  
GRI 302: Energy 2016  
103-1 Explanation of the material topic and its Boundary Environmental protection 97  
103-2 The management approach and its components Sustainability management 81
 
 
Environmental protection 97
103-3 Evaluation of the management approach Environmental protection 97 As part of our Global Sustainability Program, we have set ourselves the objective of developing and implementing a harmonized global environmental strategy, including a new global environmental policy and impact reduction targets.
302-1 Energy consumption within the organization Energy 98

 

TJ

Million MWh

Energy1

9,283.3

2.5

Electricity

4,772.4

1.3

Natural gas

4,332.6

1.1

Others2 228.4 <0.1

We use external certifications in addition to our own environmental standards if they add value. In 2020, a total of ten production sites were certified according to ISO 14001 standards. They accounted for 29 % of our total energy consumption. In addition, two production sites have ISO 50001 certification. They accounted for 21 % of our total energy consumption.
302-3 Energy intensity Energy 98  
ESG Performance Data 8
302-4 Reduction of energy consumption

Reducing the environmental impact

Reducing the environmental impact

Environmental initiative
97
GRI 303: Water and Effluents 2018  
103-1 Explanation of the material topic and its Boundary Environmental protection 97  
103-2 The management approach and its components Sustainability management 81  
Environmental protection 97
103-3 Evaluation of the management approach Environmental protection 97 As part of our Global Sustainability Program, we have set ourselves the objective of developing and implementing a harmonized global environmental strategy, including a new global environmental policy and impact reduction targets.
303-1 Interactions with water as a shared resource Water 97 As part of our Global Sustainability Program, water withdrawal as well as wastewater, including use and reuse opportunities, are analyzed. In addition, we conducted a water risk assessment for our production sites and clinics which will be further implemented into our risk management.
303-3 Water withdrawal Water 97

 

Million m3

Million liters

Water

41.7

41,687.3

Municipal water3

41.2

41,223.5

Ground water

0.5

463.8

303-5 Water consumption Water 97

Water consumption data is reported as water withdrawal. We are working to obtain further water consumption data in the future.

 

Million m3

Million liters

Water

41.7

41,687.3

Municipal water3

41.2

41,223.5

Ground water

0.5

463.8

GRI 305: Emissions 2016
103-1 Explanation of the material topic and its Boundary Environmental protection 97  
103-2 The management approach and its components Sustainability management 81
 
 
Environmental protection 97
103-3 Evaluation of the management approach Environmental protection 97 As part of our Global Sustainability Program, we have set ourselves the objective of developing and implementing a harmonized global environmental strategy, including a new global environmental policy and impact reduction targets. This includes the development of qualitative environmental goals as well as quantitative reduction targets for greenhouse gas emissions.
305-1 Direct (Scope 1) GHG emissions Greenhouse gas emissions 98

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 latest of version of the UK Department for Environment, Food and Rural Affairs (DEFRA) 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 2020, a total of ten production sites were certified according to ISO 14001 standards. They accounted for 81 % 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 Greenhouse gas emissions 98

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 latest of version of the UK Department for Environment, Food and Rural Affairs (DEFRA) 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 2020, a total of ten production sites were certified according to ISO 14001 standards. They accounted for 17 % 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.
305-4 GHG emissions intensity Greenhouse gas emissions 98  
ESG Performance Data 9
305-5 Reduction of GHG emissions Reducing the environmental impact 97 As part of our Global Sustainability Program, we have set ourselves the objective of developing quantitative reduction targets, including for emissions.
Environmental initiatives  
GRI 307: Environmental Compliance 2016  
103-1 Explanation of the material topic and its Boundary Environmental protection 97  
103-2 The management approach and its components Sustainability management 81
 
 
Compliance 93
Environmental management 97
Environmental policy  
103-3 Evaluation of the management approach Environmental protection 97 As part of our Global Sustainability Program, we have set ourselves the objective of developing and implementing a harmonized global environmental strategy, including a new global environmental policy and impact reduction targets.
We are currently  in the process of aligning our risk management according to the Task Force on Climate-related Financial Disclosures (TCFD) framework.
307-1 Non-compliance with environmental laws and regulations Commitments and contingencies 217 Relevant legal proceedings and related financial affects are disclosed in the annex of our Annual Report.
Social
GRI 401: Employment 2016
103-1 Explanation of the material topic and its Boundary Employees 88  
103-2 The management approach and its components Sustainability management 81

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


An international program team with approximately 50 contributors is working on implementing global management concepts for the above-mentioned areas.

Employee engagement:

We strive to support an ongoing dialog with our employees to foster a motivating and engaging work environment. We regularly perform surveys to actively involve employees in shaping their work environments. Our engagement strategy comprises follow-up processes in which employees, managers, and teams work on focused areas related to their respective working environments.

Learning and development:

We seek to provide our employees with learning opportunities so that they can build the skills and capabilities needed to respond effectively to an increasingly volatile, uncertain, complex, and ambiguous business environment. Our culture of learning encourages employees to contribute meaningfully to the business while enjoying career development opportunities and personal growth. Fresenius Medical Care offers 25 different apprenticeships throughout Germany.

Employment standards:

We are convinced that global employment standards positively influence the experience of our employees and increase the attractiveness of Fresenius Medical Care as an employer. For the years 2021 and 2022, we plan to create and implement several global standards. These will include topics such as engagement, learning, and development (e.g., organizational talent review), employer attractiveness (e.g., employment value proposition), compensation and benefits, and standards for inclusion and diversity.

Material sustainability topics related to our employees are managed within the HR function in close collaboration with the overall sustainability program. The HR function is responsible for our Global People Strategy and its promise: Empower people. Advance care. Inspire with our purpose and values.

Employees 88
Human Rights, Workplace Rights and Labor and Employment Principles  
103-3 Evaluation of the management approach Employees 88  
ESG Performance Data 3
401-1 New employee hires and employee turnover Employees 88 Through our focused efforts in employer attractiveness and retention, we aim to continuously improve our capability to attract, select, onboard, and retain talent. Remaining an attractive employer for both new and current employees will help Fresenius Medical Care differentiate itself from competitors and fill its positions with the right talent.
ESG Performance Data 5
GRI 403: Occupational Health and Safety 2018
103-1 Explanation of the material topic and its Boundary Health and safety 91  
103-2 The management approach and its components Sustainability management 81  
Health and safety 91
Human Rights, Workplace Rights and Labor and Employment Principles 2
103-3 Evaluation of the management approach Health and safety 91  
403-1 Occupational health and safety management system

Health and safety

91

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 Health and safety 91

Fresenius Medical Care identifies hazards at the 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 performed, appropriate actions to reduce the hazards and any related risks are identified and adopted. As an example of actions taken, it is worth highlighting that 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 taken to mitigate hazards are assigned to a specific OHS department in the region North America 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, we aim to harmonize our health and safety management systems. This will involve improving existing processes related to hazard identification and risk assessment and facilitating the sharing of best practices across all regions. In addition, we are working on a global policy for occupational health and safety. We also aim at improving the way in which employees report work-related hazards and risks.

403-5 Worker training on occupational health and safety Health and safety 91  
403-6 Promotion of worker health Health and safety 91

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.

What we offer  
403-7 Prevention and mitigation of occupational health and safety impacts directly linked by business relationships Product safety and quality 87
 

 

Health and safety 91
Global Supplier Code of Conduct 7
403-9 Work-related injuries Health and safety 91

Quantitative OHS data is currently reported at regional level. As part of the Global Sustainability Program, we are striving to define a centralized reporting process on injuries and fatalities.

In our 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 adopts actions such as offering training programs at the local level.

ESG Performance Data 7
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 occupational health and safety lies with local management. As part of our Global Sustainability Program, we have established a project for occupational health and safety. We plan to centrally report on work-related ill health in the medium term.
GRI 405: Diversity and Equal Opportunity 2016
103-1 Explanation of the material topic and its Boundary Employees 88  
103-2 The management approach and its components Sustainability management 81
 
 
Employees 88
Human rights 96
Diversity and targets 115
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

81  
Employees 88
Diversity and targets 115
405-1 Diversity of governance bodies and employees Inclusion and diversity 90 Fostering an inclusive and diverse working environment helps employees feel empowered and appreciated. We believe therefore that it's not only a smart thing to do, but the right thing to do. Our commitment to inclusion and diversity is incorporated in our Code of Ethics and Business Conduct. Striving to create a culture that promotes belonging, we have defined a global inclusion and diversity strategy in 2020. We highly value diversity, including social inclusion, both for our governance bodies and our overall workforce. We will continue to promote diversity in the future, emphasizing and embracing it as an asset. 59% of managers with direct reports are female. In the U.S., 51% of our workforce and 31% of managers with direct reports are from ethnically diverse backgrounds.

Diversity within the Management Board and the Supervisory Board has increased over time. We are committed to further increasing Board diversity including ethnic diversity. We are actively considering various diversity factors when nominating Board candidates. This also applies to ethnic diversity.

Our Management Board monitors the progress of our global inclusion and diversity efforts. In 2020, the Head of Global Human Resources informed the Management Board on a quarterly basis about inclusion and diversity matters.

Two inclusion-related questions in our employee engagement survey in 2021 (about 90,000 respondents) had more positive responses than in 2019:  “I experience trust and mutual respect in my workplace” (71% agree compared with 58% in 2019) and “I believe our working environment is accepting of diverse backgrounds and thinking” (74% agree compared with 65% in 2019). We also added a new question in 2021 (“I feel a sense of belonging at work”), which 71% of respondents answered positively.
Diversity and targets 115
ESG Performance Data 3
GRI 406: Non-discrimination 2016
103-1 Explanation of the material topic and its Boundary Employees 88  
Human rights 96  
103-2 The management approach and its components Monitoring adherence to standards 93

Our global commitment to zero tolerance for discrimination and harassment is anchored in our Code of Ethics and Business Conduct. It is further specified in our global Policy “Prohibition of Discrimination, Harassment, Sexual Harassment and Bullying”. We prohibit any form of discrimination and harassment 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. We do not tolerate any form of sexual harassment. This applies to all aspects of our work environment and extends to the conduct of our employees towards our patients and other individuals (e.g., business partners, suppliers, vendors, visitors, contractors), and vice versa.

Human rights and non-discrimination topics are integrated into our global Code of Ethics and Business Conduct training. We make compliance training mandatory for employees in all countries and locations where we are legally permitted to do so. We provide this training to help our employees understand company requirements. We also provide specific trainings on regional and local levels.

Where it is determined that applicable standards and requirements have been violated, we take appropriate remedial action to eliminate the offending behavior. This typically involves corrective action and/or disciplinary action of our employees. It can also lead to termination of employment in accordance with our global disciplinary action framework. 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 93

We have established a defined escalation process for reporting incidents. Employees who witness conduct that violates our company policy should alert any member of management or Human Resources. Incidents can also be reported via tools and channels that have been established for such reporting (e.g., the Employee Service Center in the US or the Compliance Action Line in other countries).

As part of our work within the Human and Labor Rights program, we are also further developing our procedures to monitor effectiveness including the definition of KPI to be tracked globally.
Human rights 96
GRI 412: Human Rights Assessment 2016
103-1 Explanation of the material topic and its Boundary Human rights 96  
103-2 The management approach and its components Human rights 96

Ensuring a solid understanding of our company’s actual and potential human rights impacts 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. We also assessed our impact on the workforce that makes up our supply chain.

 

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. We complemented these considerations with a saliency assessment that was performed with input from subject-matter experts from relevant functions and regions. The assessment also involved an expert from Business for Social Responsibility (BSR), a global nonprofit organization dedicated to promoting sustainability.

 

With regards to our supply chain, human rights aspects are integrated into our supplier sustainability risk assessment.

The issues in scope of our assessment include forced labor, human trafficking, child labor, freedom of association and right to collective bargaining, equal remuneration, non-discrimination, working time, grievance mechanisms/access to remedy, right to health, right to water, and right to property.
GRI 416: Customer Health and Safety 2016
103-1 Explanation of the material topic and its Boundary Product safety and quality 87  
103-2 The management approach and its components Sustainability management 81
 
 
Product safety and quality 87
Sector-specific risks 64
103-3 Evaluation of the management approach Product safety and quality 87  
Sector-specific risks 64
416-1 Assessment of the health and safety impacts of product and service categories Product safety and quality 87 For all our medical devices, in-vitro diagnostics, and pharmaceuticals, we assess and manage the risks and impacts to 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.
Product safety and quality 87
Commitments and contingencies 217
GRI 418: Customer Privacy 2016
103-1 Explanation of the material topic and its Boundary Safeguarding data 94  
103-2 The management approach and its components Sustainability management 81
 
We have formal privacy policies, one for North America, the other one for the regions Latin America, Asia-Pacific, and Europe, Middle East and Africa.
Safeguarding data 94
Code of Ethics and Business Conduct 18
Notice of Privacy Practices  
103-3 Evaluation of the management approach Safeguarding data 94 The implementation of the General Data Protection Regulation was audited in several jurisdictions by the Global Internal Audit department in 2020.
418-1 Substantiated complaints concerning breaches of customer privacy and losses of customer data     Number of complaints received from outside parties and substantiated by the organization in 2020: 0.
GRI 419: Socioeconomic Compliance 2016
103-1 Explanation of the material topic and its Boundary Compliance 93  
103-2 The management approach and its components Sustainability management 81

We are continuing to evolve our global compliance program. The appointment of the Independent Compliance Monitor (“Monitor”) in August 2019 has helped us to further focus attention on a number of ongoing initiatives. To closely coordinate all activities, we are in contact with the Monitor on a near daily basis. We continue to improve the culture of the Company regarding compliance, with 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. In addition, our senior managers participated in a half-day seminar to learn the necessary skills to further foster and communicate a culture of compliance.

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 also working to redesign and simplify policies and procedures to make them more user-friendly and operational across the Company. Currently, more than 40 policies and procedures are in scope of this initiative.

We are dedicating resources to implement our third-party due diligence program. This includes expanding our mergers and acquisitions (M&A) due diligence to ensure that there is 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. 

In addition, we have enhanced our financial controls infrastructure with more than 150 new internal controls. These are designed to raise red flags in instances where questionable transactions are detected.

We also continue to emphasize the importance of internal reporting and investigations. Our Global Investigations function evaluates and examines matters in coordination with the Global Legal Function. Cases, statistics, and trends are assessed in regular 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 privileged 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 actions.

Furthermore, we have expanded the Global Internal Audit capability by adding resources and focusing internal audits in high-risk areas on anti-corruption. Accordingly, we conducted three anti-corruption-related audits of business partners in 2020 and plan to perform another 20 in 2021. 

Compliance 93
103-3 Evaluation of the management approach Compliance 93
419-1 Non-compliance with laws and regulations in the social and economic area Risks and opportunities report 92 Risks from litigation and legal proceedings are reported in our risks and opportunities report. Legal matters that Fresenius Medical Care currently deems to be material or noteworthy are described in the annex of our Annual Report.
Commitments and contingencies 217
Additional Material Topic: Quality of Care and Patient Satisfaction
103-1 Explanation of the material topic and its Boundary Responsibility for patients 84  
103-2 The management approach and its components Sustainability management 81
 
 
Responsibility for patients 84  
103-3 Evaluation of the management approach Responsibility for patients 84  
Additional Material Topic: Corporate Culture incl. Tone from the Top
103-1 Explanation of the material topic and its Boundary Promoting integrity 93  
103-2 The management approach and its components Letter to our shareholders 6
 
 
Corporate strategy and objectives 22
Sustainability management
81
CEO speech Annual General Meeting 2020 10
Code of Ethics and Business Conduct 4
Corporate culture  
103-3 Evaluation of the management approach Promoting integrity 93 In 2020, we intensified our leadership communication efforts to employees worldwide, to promote a culture of ethical business behavior. This has resulted in the implementation of more than 40 communication measures based on the “tone from the top / tone from the middle” approach.

In part subject to extrapolations. Including energy consumption of our manufacturing sites as well as electricity consumption in our dialysis centers.Terajoule conversion factors determined by eco-reporting tool Schneider Electric Resource Advisor.

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

3 In part subject to extrapolations.