Fresenius Medical Care has reported the information cited in this Global Reporting Initiative (GRI) content index for the period from 1 January 2023 to 31 December 2023 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 | |
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The organization and its reporting practices | |||
2‑1 | Organizational details | Imprint and contact Notes to consolidated financial statements: The Company Regional organization |
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2-2 | Entities included in the organization’s sustainability reporting | Non-Financial Group Report: About this report Notes to consolidated financial statements: Principal subsidiaries |
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2-3 | Reporting period, frequency and contact point | Contact | The reporting period is from January 1 to December 31, 2023. In compliance with German Commercial Law, we apply a yearly reporting cycle. Our most recent combined Annual and Non-Financial Group Report 2023 was published on March 22, 2024. |
2-4 | Restatements of information | Employees: Employee overview | |
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 |
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Activities and workers | |||
2-6 | Activities, value chain and other business relationships | Overview of the Group: Business model |
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 | ||
2-8 | Workers who are not employees | Currently, we have implemented local processes to track non-employees. 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 GovernanceSustainability management: Sustainability governance |
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2-10 | Nomination and selection of the highest governance body | Declaration on Corporate Governance: The General Partner and its bodies |
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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 |
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2-12 | Role of the highest governance body in overseeing the management of impacts | Sustainability management: Sustainability governanceDeclaration on Corporate Governance: Lead Independent Director |
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2-13 | Delegation of responsibility for managing impacts | Sustainability management: Sustainability governanceRisks 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 |
The Non-Financial Group Report is reviewed and approved by our Chief Executive Officer, Helen Giza. |
2-15 | Conflicts of interest | Report by the Supervisory Board: Corporate Governance structure |
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 | ||
2-17 | Collective knowledge of the highest governance body | Sustainability management: Sustainability governance Declaration on Corporate Governance: Independence Qualification matrix for the members of the Supervisory Board of the Company Supervisory Board website: Lead Independent Director and ESG expertise |
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2-18 | Evaluation of the performance of the highest governance body | ||
2-19 | Remuneration policies | ||
2-20 | Process to determine remuneration | Compensation Report: Compensation of the members of the Management Board and Supervisory Board | |
2-21 | Annual total compensation ratio | Compensation Report: Comparative presentation of the development of the compensation |
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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 |
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2-23 | Policy commitments | Code of Ethics and Business Conduct Human Rights Statement Policies and standards |
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2-24 | Embedding policy commitments | Sustainability management: Strategy Code of Ethics and Business Conduct Human Rights Statement Supplier 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 |
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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 |
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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. These include Econsense and the Global Industrial Relations Network (a network of the International Organization of Employers). |
Stakeholder engagement | |||
2-29 | Approach to stakeholder engagement | Sustainability management: Stakeholder inclusion |
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2‑30 | Collective bargaining agreements | Employees: Dialogue with employees and their representatives | Collective bargaining agreements apply to different groups of employees within Fresenius Medical Care, depending on local laws and practices. In Europe, these apply to 51% of our employees and worldwide to 22%. |
GRI Standard | Link | Comment | |
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3-1 | Process to determine material topics | Sustainability management: Material topics | |
3-2 | List of material topics | Sustainability management: Material topics | |
3‑3 | Management of material topics | Sustainability management: Material topics |
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GRI 201: Economic Performance 2016 | ||||||||||||||||||||||||||||||||||||||||||||||||
201-1 | Direct economic value generated and distributed | Overview of the Group: Performance indicators excluding special items |
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201-2 | Financial implications and other risks and opportunities due to climate change | Risks and Opportunities Report: ESG requirements |
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201-3 | Defined benefit plan obligations and other retirement plans | Notes to consolidated financial statements: Employee benefit plans |
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201-4 | Financial assistance received from government | Economic Report | ||||||||||||||||||||||||||||||||||||||||||||||
GRI 204: Procurement Practices 2016 | ||||||||||||||||||||||||||||||||||||||||||||||||
204-1 | Proportion of spending on local suppliers | The amount spent on local suppliers represents 37% 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 |
In 2023, 66 markets have been assessed for risks related to corruption. |
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205-2 | Communication and training about anti-corruption policies and procedures | Our anti-corruption policies and procedures have been communicated to all Management Board and Supervisory Board members, as well as employees. Likewise, training has been provided to employees, governance bodies and high-risk/selected third parties. Below you will find an overview of number of participants in compliance training:
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205-3 | Confirmed incidents of corruption and actions taken | Compliance |
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. |
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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. In 2023, after Fresenius Medical Care’s change in legal form as well as after the deconsolidation the Tax CMS has been adjusted to the updated tax related processes and tax risks. |
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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. |
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207‑4 | Country-by-country reporting |
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Additional Material Topic: Innovation and R&D | ||||||||||||||||||||||||||||||||||||||||||||||||
3-3 | Management of material topics | Environmental protection: Energy and climate change
Patients: Health equity |
GRI Standard | Link | Comment | |||||||||||||||||||||||||
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GRI 302: Energy 2016 | |||||||||||||||||||||||||||
302-1 | Energy consumption within the organization |
We have established internal environmental standards, which we complement with external certifications where necessary or appropriate. In 2023, a total of ten production sites were certified according to ISO 14001 standards. They accounted for 33% of our total energy consumption. In addition, two production sites have ISO 50001 certification. They accounted for 22% of our total energy consumption. 1 Including the energy consumption of our production sites and the electricity consumption of in-center treatments in our dialysis clinics. 2 Subject in part to extrapolations. 3 Including fueloil, diesel, liquid gas, and district heating. Excluding mobile assets. |
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302-3 | Energy intensity | Environmental protection: Energy and climate protection ESG Performance Data |
Energy consumption (MWh)4 / € 1million revenue = 131.1 Energy consumption (MWh)4 / FTE = 22.7 4: Including the energy consumption of our production sites and the electricity consumption of in-center treatments in our dialysis clinics. |
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302-4 | Reduction of energy consumption | Environmental protection: Energy and climate protection Environment website: Environmental initiatives |
As a direct result of energy efficiency and reduction initiatives in our production sites in 2023, we expect to reduce our annual energy consumption by 22,900 MWh. The initiatives include electricity-, natural gas- and LPG savings. |
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GRI 303: Water and Effluents 2018 | |||||||||||||||||||||||||||
303-1 | Interactions with water as a shared resource | Environmental protection: Water management | To safeguard the responsible use of water resources, we continued to analyze which of our sites are in water-stressed areas with the help of the Aqueduct Water Risk Atlas of the World Resources Institute (WRI). We use the results from the WRI scenario analysis to identify how water stress will develop around the world under different scenarios. To define optimization and improvement measures for production sites and dialysis clinics in areas with extremely high-water stress, we aim to develop a Sustainable Water Management Strategy by 2026. | ||||||||||||||||||||||||
303-2 | Management of water discharge related impact | Environmental protection: Water management | We expanded the collection and tracking of water discharge data for our production sites. In addition, we assessed our methodology for reporting on water discharge for our clinics. We expect to publish water discharge figures for our production sites and clinics in our reporting for the financial year 2024. | ||||||||||||||||||||||||
303-3 | Water withdrawal | Environmental protection: Water management |
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303-4 | Water discharge | Environmental protection: Water management | We expanded the collection and tracking of water discharge data for our production sites. In addition, we assessed our methodology for reporting on water discharge for our clinics. We expect to publish water discharge figures for our production sites and clinics in our reporting for the financial year 2024. | ||||||||||||||||||||||||
GRI 305: Emissions 2016 | |||||||||||||||||||||||||||
305-1 | Direct (Scope 1) GHG emissions | 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 53% 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. |
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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 2023, a total of ten production sites were certified according to ISO 14001 standards. They accounted for 12% 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. |
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305-3 | Other indirect (Scope 3) GHG emissions |
All scope 3 emissions are calculated in accordance with the GHG-Protocol. Upstream categories are calculated based on spend except for category 3.3 which is calculated in accordance with the average-data method and considers the energy volumes reported in the section "Energy". Downstream categories are calculated based on screening of life-cycle assessment data. These assessments identify the life-cycle phase with the highest impact as well as the processes and materials we must focus on to improve the eco-performance of our products and services. |
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305-4 | GHG emissions intensity | GHG emissions8 (tons CO2e equivalents / €1 million revenue) = 33.8 |
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305-5 | Reduction of GHG emissions | Environmental protection: Energy and climate protection | As a result of the energy reduction initiatives mentioned in 302-4, we expect to prevent scope 1 and 2 emissions by 5,500 metric tons of CO2e. |
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GRI 306: Waste 2020 | |||||||||||||||||||||||||||
306-1 | Waste generation and significant waste-related impacts | Environmental protection: Water management | In the health care industry, strict hygiene requirements apply to the materials used and the safe disposal of hazardous waste to prevent it from causing harm to patients, employees, or the environment. We are committed to reducing waste and aim to continually improve waste management. Improving waste disposal and recycling We continued to analyze the waste streams in our production sites and dialysis clinics in all regions. In 2023, we also established global waste reporting processes for our business segments including total waste, hazardous and non-hazardous waste, as well as information on waste disposal methods. For example, we performed waste audits in the U.S. in 2023 to improve our awareness of waste types and gain an understanding of ways to reduce waste. Our findings will support us in analyzing how we generate waste and enhance our waste estimation approach. Additionally, we conducted an analysis to optimize waste disposal and reduce related disposal costs, for example, by installing smaller waste bins and optimizing the frequency of bin collection. In 2023, we extended the scope of our waste assessment to include resource consumption and circular economy practices. This will enable us to evaluate the potential product and market benefits of a circular design such as cost savings due to fewer individual components, or the upgradeability of products. To improve the recycling and circularity of our products, we are currently working with different suppliers and institutions to optimize efficient waste disposal, improve recycling and develop a circular approach. |
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306-2 | Management of significant waste-related impacts | Environmental protection: Water management | |||||||||||||||||||||||||
306-3 | Waste Generated | Environmental protection: Waste management |
Total Waste: 183,050 metric tons |
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306-4 | Waste diverted from disposal | Environmental protection: Waste management | |||||||||||||||||||||||||
306-5 | Waste diverted from disposal | Environmental protection: Waste management | |||||||||||||||||||||||||
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 have trained our Procurement organization on the new processes and implemented the sustainability-related selection criteria in March 2023. | ||||||||||||||||||||||||
308‑2 | Negative environmental impacts in the supply chain and actions taken | We have analyzed the environmental and social impact associated with our supply chain and are currently working on the definition of actions to be taken; we had no contract terminations as result of the assessment so far. |
GRI Standard | Link | Comment | |
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GRI 401: Employment 2016 | |||
401-1 | New employee hires and employee turnover | Employees ESG Performance Data |
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401-2 | Benefits provided to full-time employees that are not provided to temporary or part-time employees |
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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 Statement |
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 work continuously 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. We are assessing the possibility to digitalize these processes in the coming years to ensure a global alignment. All actions to mitigate hazards are assigned to a specific EHS 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. Thanks to the newly introduced system some locations have the possibility to use a voluntary available investigation tool. |
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. |
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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. Regular consultations take place yearly at regional level. In 2023 the OHS global function has joined some of these meetings aiming at hearing feedback and needs directly from country representatives. |
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 |
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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. |
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403-9 | Work-related injuries | Employees: Occupational health and safety |
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. In the last years 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 which can be consulted in the NFR and the KPI performance list: number of work-related fatalities, total recordable injury frequency rate (TRIFR), and lost time injury frequency rate (LTIFR) and continuously improve the quality of our data through specific controls. In our clinics and plants, the most frequently reported injuries do not cause more than 1 day lost, this is due to the fact that these are mostly injuries caused by needles and other sharps. |
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. In 2023 we have aligned globally on the definition of such events and in 2024 we plan to finalize the set up of internal reporting. |
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GRI 404: Training and Education 2016 | |||
404-1 | Average hours of training per year per employee | Employees: Attracting and developing talent ESG Performance Data |
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404-2 | Programs for upgrading employee skills and transition assistance programs | ||
404-3 | Percentage of employees receiving regular performance and career development reviews | Employees: Attracting and developing talent | The performance management module in our global HR system that we implemented in 2023 allows managers and employees to work together to plan, monitor, and review the employee’s development goals, performance and overall contribution to the success of the organization. The module is currently accessible to 70% of our employees, surpassing the goal of 50% coverage that we set for ourselves in 2022. We intend to make this process available to the remaining employees by the end of 2026. |
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 |
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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 | Code of Ethics and Business Conduct |
We support equal opportunities and do not tolerate any form of discrimination or harassment based on national or ethnic origin, skin color, social origin, health status, citizenship, disability status, sexual orientation, age, gender or gender identity, gender expression, marital status, pregnancy, political opinion, religion or belief, and any other criteria as protected by local laws and regulations. We are committed to fostering a sense of belonging which allows all individuals to thrive and reach their full potential. Our global commitment is inter alia stipulated in our Code of Ethics and Business Conduct and our Human Rights Statement. It is further specified in our policies and procedures. To raise awareness for our company position on human rights related topics including prevention of discrimination we integrated those into our mandatory annual e-learning on the Code of Ethics and Business Conduct. Participation in this training is regularly monitored and reported to the Management Board. Additionally, there are local trainings provided, as needed. 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 | Supplier management |
We recognize the freedom of association and the right to collective bargaining, including the rights of our employees to freely choose whether or not to form and/or be represented by a particular collective body or a trade union, in accordance with the laws of the place of employment. Our global commitment is inter alia stipulated in our Code of Ethics and Business Conduct and our Human Rights Statement. It is further specified in our policies and procedures. To raise awareness for our company position on human rights related topics incl. freedom of association and collective bargaining, we integrate related aspects into our mandatory annual e-learning on the Code of Ethics and Business Conduct. Participation in this training is regularly monitored and reported to the Management Board. Our Human Rights Statement and Global Supplier Code of Conduct summarize related expectations towards our suppliers. We expect them to respect the rights of workers to associate freely, to join or not join labor unions and to seek representation in accordance with local laws. We also have defined sustainability-related selection criteria for new suppliers, further outlined in GRI 308-1. |
GRI 408: Child Labor 2016 | |||
408-1 | Operations and suppliers at significant risk for incidents of child labor | Supplier management |
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 Human Rights Statement, Supplier Code of Conduct and our Compliance Brochure for our Business Partners. It is further specified in our policies and procedures. To raise awareness for our company position on human rights related topics including child labor, we integrate related aspects into our mandatory annual e-learning on the Code of Ethics and Business Conduct. Participation in this training is regularly monitored and reported to the Management Board. Moreover, our Global Supplier Code of Conduct requires that suppliers shall condemn exploitative child labor and shall not employ workers under the minimum age for regular employment as defined by applicable national legislation or international conventions. We also have a defined sustainability-related selection criteria for new suppliers, further outlined in GRI 308-1. |
GRI 409: Forced or Compulsory Labor 2016 | |||
409-1 | Operations and suppliers at significant risk for incidents of forced or compulsory labor | Supplier management |
We do not tolerate the use or threat of violence, or any other form of coercion. We strictly forbid using, supporting, or approving any form of exploitative labor, child labor or forced labor. Employment relationships must be based on voluntary participation. Hence, our employees can choose to terminate their employment of their own free will by respecting a reasonable pre-notification period, as applicable. Our global commitment is inter alia stipulated in our Code of Ethics and Business Conduct and our Human Rights Statement. It is further specified in our policies and procedures. To raise awareness for our company position on human rights related topics including forced labor, we integrate related aspects into our mandatory annual e-learning on the Code of Ethics and Business Conduct. Participation in this training is regularly monitored and reported to the Management Board. Our Global Supplier Code of Conduct stipulates that suppliers shall take a clear stance against forced labor and any form of exploitative child labor and shall not engage in any form of non-voluntary, forced or compulsory labor. |
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 have trained our Procurement organization on the new processes and implemented the sustainability-related selection criteria in March 2023. |
414-2 | Negative social impacts in the supply chain and actions taken | We have analyzed the environmental and social impact associated with our supply chain and are currently working on the definition of actions to be taken; we had no contract terminations as result of the assessment so far. | |
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 | 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 |
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 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). Outside of US, Fresenius Medical Care also detected 88 data breaches and 48 of these impacted on patients’ information. Many of these were not reportable according to applicable law. |
Additional Material Topic: Resource use and circularity | |||
3-3 | Management of material topics | Environmental protection: Improving waste disposal and recycling | In 2023, we extended the scope of our waste assessment to include resource consumption and circular economy practices. This will enable us to evaluate the potential product and market benefits of a circular design such as cost savings due to fewer individual components, or the upgradeability of products. To improve the recycling and circularity of our products, we are currently working with different suppliers and institutions to optimize efficient waste disposal, improve recycling and develop a circular approach. |