The guidelines of our Code of Ethics and Business Conduct are mandatory for all the Company’s employees and managers.
Fresenius Medical Care takes pride in fostering an active and engaged speak-up culture. We value open feedback - as a key driver for our success, for innovation and for continuous improvement. Our aim is excellence in doing business with a strong ethical backbone.
Our employees, as well as people outside of our organization, are invited and encouraged to share their concerns via multiple channels:
The latter offers support in numerous languages - anonymously and confidentially, as adequate to the reporters’ requirements and the specific situation.
All reports of potential misconduct, no matter the intake channel, are routed to our experienced investigators from the Global Investigation Department, an independent and impartial function within Compliance. The Global Investigation Department is mandated by the Management Board to receive, assess, process, investigate reports and ensure the company takes remedial actions where necessary. As appropriate considering the nature and substance of the report, the Global Investigation Department fulfills its tasks with the support of other departments within the Fresenius Medical Care Group. The employees of the Global Investigation Department are mandated to perform these tasks independently and impartially according to their due discretion, in compliance with legal requirements, the procedural principles of the Fresenius Medical Care Reporting Potential Violations Policy.
In this respect, the employees of the Global Investigation Department are expressly not subject to any instructions from other bodies within the Fresenius Medical Care Group, including the Management Board of Fresenius Medical Care and its members.
Please trust that our professionals attend to matters swiftly, discreetly and without any bias. Investigations are handled with the highest possible level of confidentiality.
Ethical conduct is our guiding principle. Our business success is founded on integrity. One of the facets of our culture of integrity is our firm and uncompromising commitment to protect reporters and individuals supporting an investigation – internal and external – from retaliation. People who raise their concerns in good faith enable us to identify and address potential misconduct and deficits in the way we act – and we sincerely appreciate that.
This is why we take every report made on reasonable grounds seriously and address it with a sense of urgency. We commit to professional, unbiased, confidential and neutral investigations according to a consistent process.
Ethics, transparency - and protection of those who trust us with a report or support us in an investigation - go hand in hand at Fresenius Medical Care. Worldwide. Every Day.
We have also set up an external hotline system – called the Compliance Action Line – operated by an independent, certified third-party vendor for our employees and related third parties to report potential violations of laws or company guidelines.
In 2022, we received 3,399 reports via our reporting channels. While our hotline is set up to report compliance concerns, we also receive non-compliance-related calls on patient care, information security reports, and human resources. These calls are forwarded to the appropriate departments.
Each report is reviewed based on more than 30 allegation categories. The reports covered topics such as anti-corruption, data protection, and human resources / workplace. We investigate all cases of potential misconduct, take corrective measures on a case-by-case basis, and track their implementation. Of 135 compliance investigations closed in 2022, approximately 50% were found to be actionable. Actionable means that the investigations resulted in findings that prompted us to improve processes, adjust policies or internal controls, or take disciplinary action.