Our grievance mechanism

To make it as easy as possible for potentially affected parties, we offer the following reporting channels:

• An external grievance and whistleblowing system operated by an independent provider:
  https://www.bkms-system.net/fse-compliance  
  
  The BKMS® reporting system is a web-based application. It offers the opportunity to submit a report without any restrictions in terms of location or time. The system is currently available in German, English and Spanish. The system is certified according to European data protection law and meets the highest data security standards. Neither the operator nor third parties have access to the information. Only the responsible members of the Fresenius Business Integrity Team can do so and they will of course treat your information confidentially and process it conscientiously. 
  
  Reports can also be submitted anonymously. If you choose to stay anonymous, no conclusions can be drawn about your identity. A protected mailbox within the reporting system, accessible only to you, enables anonymous communication with the responsible members of the Fresenius Business Integrity Team if desired.
  
  Information can also be sent to our functional e-mail addresses which have been set up especially for this purpose: 
  
  Reports concerning the violation of human rights can be sent to: humanrights@fresenius.com   
  
  All other reports should be sent to: corporate-compliance@fresenius.com 
   
• Reports in writing (letters) can also be addressed to:
  
  Fresenius SE & Co. KGaA 
  Business Integrity 
  Else-Kröner-Str. 1
  61352 Bad Homburg v.d.H.
  Germany
   
• Employees and temporary workers employed by Fresenius' service providers can also contact the Fresenius Business Integrity Team by e-mail, telephone or in person. You can find the relevant contact person on the Fresenius intranet.

You can report any violations of applicable laws and Fresenius-internal regulations using the reporting channels described above. These include, e.g., corruption, competition and antitrust violations, data protection violations, violations of employee rights, as well as accounting, finance and tax violations ("compliance violations"). In addition, you can report actual or potential violations of human rights or environmental obligations related to our business activities and our direct and indirect suppliers ("human rights violations"). 

In your report, please describe the facts of the case as clearly and in as much detail as possible. You can use the following questions as a guide: 
What?         Who?         When?         How?          Where? 

If you use these questions as a guidance, we will be able to process your report more easily. If you use our web-based reporting system, after a brief information and security prompt, you will be asked to indicate the focus area of your report and to provide information on the parties involved and the time period of the violation.

It is always helpful that you are available for further queries and clarification. If you are willing to do so, but still wish to remain anonymous, please use the option of the protected mailbox available to you in our web-based reporting system.
 

All reports are processed by specially trained employees of our Business Integrity Team. Depending on the circumstances, it may be necessary to involve other subject matter experts and functions to further clarify an incident. 

For the purpose of transparent communication, you will find below a description of the typical course of the procedure:
 

• Report intake and documentation
  As soon as your report is received in one of the channels described above, but at the latest after seven days, you will receive an acknowledgement of receipt. It may also be helpful to further process the matter together with you. E.g., in the case of human rights violations, consensual agreed solutions may be appropriate, depending on the severity and the issue.
• Plausibility check and categorization of report
  As soon as it is determined that the received report falls within the scope of the procedure, the report will be carefully checked for plausibility and categorized in order to forward it to the responsible function where needed. If an investigation is not possible due to a lack of sufficient information we will try to contact you – if you have not submitted your report anonymously and without opening a secure channel of communication – to request further information. 
• Fact finding
  We will examine the facts comprehensively and conscientiously. All reports will be investigated appropriately. In addition to obtaining background information – as far as possible – we will review documents, analyze data and conduct interviews. In addition, the investigation may also include discussing the facts with you and, if necessary, reaching a friendly settlement of the dispute.
• Remediation
  If we have identified a violation, our top priority is to remediate it quickly. In addition, disciplinary measures can be taken to sanction individual misconduct and further process improvements can be implemented to avoid reoccurrence of the violation in the future. 
• Review of the mitigating measures and the result
  In the case of human rights violations, we offer to evaluate the measures and achieved results together with you in order to find out whether they were or are effective or whether they need further improvement.

Fresenius commits itself and all employees involved in this process to handle all information professionally, independently and impartially, carefully and confidentially. 

In accordance with the principles of fair trial, all relevant circumstances of the case will be taken into account. In addition, the principle of proportionality must always be upheld. Accused persons are presumed innocent as long as the opposite has not been proven.

Our employees involved in the various process steps are experienced in dealing professionally with reports on violations and the underlying facts. They receive ongoing training on our processes and the relevant topics. In addition, they work on incoming reports independently of instructions. 

Reports on violations – and the underlying issues – can vary widely in their scope and complexity. It is therefore difficult to set a generally applicable timetable for investigations. However, we are committed to conducting and completing internal investigations as quickly and efficiently as possible.

After the conclusion of the procedure – at the latest after the expiry of three months after receipt of the report – and insofar as this does not jeopardize the investigation, you will receive a final summary and feedback on your report as well as on the measures taken, taking into account the applicable data protection regulations and other confidentiality requirements as well as safeguarding overriding company interests. 

In our Fresenius Code of Conduct and our Group-wide process descriptions, we have made clear that we will not tolerate any retaliation against employees who in good faith report possible or actual violations or support investigations. This protection is also served by our measures to maintain confidentiality ('need-to-know' principle) and strict rules for dealing with conflicts of interest. In the case of external reporters, we strive to achieve a comparable level of protection and have formulated corresponding expectations in our Code of Conduct for Business Partners.

A violation of this prohibition against retaliation may be reported and investigated under the same rules as described herein.

The results of our risk analysis and the findings on potential target groups of our grievance and whistleblower channels will be incorporated into the further development of our grievance and whistleblowing procedures and the processing of grievances and whistleblowing reports. Based on our findings, we will review the effectiveness of the procedure described above on an annual basis or more frequently if required. If necessary, we will make appropriate adjustments and changes with regard to the accessibility and process of the procedure. In order to continuously improve, we also welcome suggestions and feedback from whistleblowers.

As we always strive for transparency, we regularly publish information on the number of reports received, the topics, the conclusions drawn from the reports and the measures taken. This publication is always anonymous.