To prevent, eliminate, or minimize human rights risks, both the Group and each business segment take appropriate preventive measures tailored to the individual case in our own business and in the value chain. In cases where our business activities have caused or contributed to human rights violations, we take appropriate and effective case-specific remedial action.
Preventive Measures
The following overview provides a non-exhaustive summary of potential standard preventive measures for Fresenius’s own operations and / or the value chain.
Own Operations
Standard preventive measures within our own operations include, among others, a binding Code of Conduct for our employees, guidelines on social and labor standards, as well as management systems for occupational health and safety.
In addition to training on human rights and communication measures related to our Human Rights Statement, our Internal Control System (ICS) and regular internal audits strengthen the implementation and monitoring of our human rights due diligence obligations.
Value Chain
Our measures within the value chain include, among other things, a Code of Conduct for business partners as well as risk-based training on human rights requirements, including information on the grievance mechanism.
These are complemented by risk-based assessments and ongoing monitoring of our business partners. Human rights and environmental clauses in contracts, along with our memberships in industry and multi-stakeholder initiatives, further support the implementation of our due diligence obligations throughout the value chain. In addition, within the scope of our influence, we develop specific prevention measures tailored to the results of regular and event-driven risk analyses and document these accordingly.
Further information on specific preventive measures can be found under Risk Analysis and Impact as well as in the 2024 CSRD report in the chapters “Own workforce” and “Workers in the value chain”.
What are human rights? How can I report a possible violation? And what does the term human rights due diligence mean? Our employees and business partners shall know the answers to these questions if we are to put our commitment to human rights into practice.
For this reason, we have developed a global human rights training course – together with colleagues from different parts of our organization. This training is mandatory for all our employees. It will also serve as a supporting measure in our collaboration with our suppliers as of 2025. Which suppliers should take part in the training depends on their respective risk profiles. In this way, we want to actively contribute to the further development of our corporate culture and create a common understanding of due diligence obligations in our value chain.
Remedial measures
The aim of any remedial action is to end or minimize and, if possible, reverse the human rights or environmental violation. To measure effectiveness, we review the implementation of the measures at a case-specific interval. If necessary, we initiate further measures. A process is only considered closed when all remediation measures have been fully implemented.
To address negative impacts on rightsholders, we have developed a toolbox to provide practical support for human rights specific remediation measures. This is aimed at colleagues involved in investigating human rights and environmental violations affecting employees of Fresenius as well as workers in the value chain and consists of various components. These include general guidance on remediation in accordance with the LkSG and international human-rights-related standards and principles. It also includes guidance on dealing with specific human rights violations and a handout for evaluating the effectiveness of remediation.
Appropriateness and effectiveness review of the measures taken
We continuously review the effectiveness of preventive and corrective measures after implementation. This evaluation also incorporates new insights, such as those from our risk analysis and feedback from the affected stakeholder groups. If required, we initiate targeted adjustments to further enhance the effectiveness of the measures.
Human Rights at Fresenius
Our Human Rights ProgramContact
Fresenius SE & Co. KGaA
Else-Kröner-Str. 1
61352 Bad Homburg
Germany
humanrights@fresenius.com
Human Rights Program
Our Human Rights Program Group-wide Governance & Responsibilities Risk Assessment & Impact Grievance Procedure & HandlingWhistleblowing system
Reports on possible human rights or other types of compliance violations can be reported around the clock, either anonymously or by name, via our whistleblower system*:
Phone number: +49 (0) 800 181 1338*
https://freseniusgroup.ethicspoint.com
More infos about our grievance mechanism
*The prices of your mobile or landline contract apply
Human rights risks can change over time. We therefore conduct annual and event-related risk analyses. In the 2024 reporting period, this was done in the third and fourth quarters. An event-related risk analysis was not conducted.
Process for identifying and assessing human rights risks
Identifying and assessing human rights risks in our own company and in our value chain is a comprehensive process that consists of risk identification, risk analysis, and risk assessment. We follow a risk-based approach that can be divided into three phases and is explained below with the help of the fictional protagonist, John.*
*The persons and stories depicted in these images are purely fictional. Any resemblance to actual persons is purely coincidental and unintentional.
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Risk identification
John works in the Fresenius Human Rights team. In the first phase, he conducts a country- and industry-specific abstract risk analysis to identify potential human rights risks.
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Gap analysis
To evaluate which of the identified potential risks could also be actual risks, John conducts a gap analysis in the second phase. For this, he uses standardized questionnaires, for example, to record processes, responsibilities, and procedures for each potential risk area. This applies to our own business as well as to the value chain. John closely involves the risk owners and experts from the affected departments in these gap analyses.
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Risk assessment
In the third and final step of the risk analysis, John, together with the experts from the affected departments, analyzes and evaluates the gaps and risks identified, taking into account the impact on those affected and the likelihood of occurrence. For prioritized risks, they then define remedial and preventive measures.
Curious about how we weigh and prioritize risks? Here's how:
To weight and prioritize risks, we introduced a comprehensive methodology for assessing their impact and likelihood of occurring. Using this method, the risks are plotted on a matrix (4x4).
The evaluated impact on those affected ranges from “low” to “severe”. It is assessed using four evaluation criteria: scope, scale, possibility for remedial action, and company involvement.
Probability of occurrence ranges from “unlikely” to “almost certain”. It is assessed using three different evaluation criteria: process evaluation, evaluation of similar cases which have already arisen, and context factors which could increase the likelihood of the risks materializing.
Results of the risk analysis
We carry out a regular risk analysis of human rights topics for both our own businesses and our supply chains in accordance with the specific requirements of applicable international and national laws and regulations. As part of this risk analysis, we identify areas that we consider to have high priority due to the potential severity of possible violations and due to our ability to influence them.
Prioritized risk areas for own operations
The risk analysis for the 2024 reporting year confirmed the following existing prioritized risk areas for our own operations and revealed additional potential risks:
- Discrimination and unequal treatment
- Freedom of association and collective bargaining
- Occupational health and safety in the workplace
Preventive measures to mitigate risks in our own operations
As a healthcare Group, we not only bear responsibility for the well-being of our patients, but also for the health and safety of our employees. We implemented a Group Policy on Social and Labor Standards. The guideline describes our global social and labor law minimum standards. We expect our employees and managers in all business segments of the Fresenius Group to comply with this guideline without exception. Lower standards are not acceptable. Should laws or practices in countries where we operate restrict or contradict the standards set out in this policy, we will apply the policy to the extent permitted by local laws . Moreover, the Fresenius Code of Conduct stipulates that we take the necessary measures to protect our employees and prevent work-related accidents and illnesses.
Creating a safe and healthy working environment is a priority for us. When it comes to health protection, prevention is our basic principle: We therefore provide our employees with comprehensive programs to promote their health and prevent work-related illnesses. The return of employees after an illness is regulated, for example, by the company integration management system.
We have introduced numerous management systems and measures throughout the Group and adapted them to the business models of the business segments. They focus on occupational health and safety in the production area as well as occupational health management for employees in healthcare facilities or in administration.
All locations are also subject to the respective local regulations and laws. Compliance with these regulations is ensured at local level. In addition to statutory regulations, internal guidelines and directives such as management manuals and standard operating procedures also play a significant role in occupational health and safety. In addition to the Group-wide Fresenius Code of Conduct, the business segments have their own guidelines that regulate occupational health and safety, e.g. the Clinical Code of Conduct for the rehabilitation and nursing units and medical personnel in the healthcare services market segment.
The internal requirements are supplemented by corresponding internationally recognized standards for management systems such as ISO 45001 at some locations as well as other certifications in accordance with ISO or national standards. The overarching aim of the ISO 45001 management system is to continuously improve occupational health and safety management, align it with internationally recognized methods and ensure the effectiveness of existing procedures and systems. To drive this forward, we are consistently expanding the number of entities certified to this standard.
Further Information can be found in the 2024 CSRD report from page 216.
To minimize potential human rights risks connected to our business activities, we have taken further preventive and mitigating measures. These include, for example, training that we offer to our workforce. The Fresenius Group, for instance, conducts regular occupational health and safety training to prevent incidents in its fields of operation.
To sustainably promote tolerance and appreciation within our teams in the long-term and to mitigate the risk of discrimination, it furthermore is not only necessary to have a corresponding culture that is exemplified by the management bodies; employees also receive training and further education on the topic of diversity.
The elimination of discrimination is both a component of our Group-wide compliance programs and a key element of our Human Rights Program. These concepts are supplemented by suitable controls, process documentation, training concepts, awareness-raising measures, and the use of whistleblower systems. In this way, we want to ensure that discrimination, including harassment, is prevented, contained, or combated in our operational business if we become aware of violations, risks, or impacts.
Another central element is the successive roll out of a company-wide human rights training for our employees. The training aims at educating our employees on this important topic – not only about their personal human rights, but also about the contribution that everyone can make in their daily work. It further imparts knowledge about individual rights and how to deal with possible human rights violations.
In addition, we have implemented individual and local measures to provide our employees with the best possible protection within our sphere of influence. For instance, at high-risk locations, we deploy more security staff than is typically found in hospitals to better protect our employees and patients around the clock. Furthermore, a monthly committee with participants from local management and employees has been established to strengthen the dialogue.
Further details on preventive and remedial measures, as well as on appropriateness and effectiveness, are available here.
Prioritized risk areas for our value chain
The risk analysis for the 2024 reporting year confirmed the following existing prioritized risk areas for our value chain and revealed additional potential risks:
- Remuneration and appropriate compensation
- Discrimination and unequal treatment
- Environmental pollution
- Freedom of association and collective bargaining
- Occupational health and safety in the workplace
Preventive measures to mitigate risks across our value chain
To counter the potentially negative effects, we have initiated and implemented further preventive measures in addition to existing ones. With the risk-based implementation of human rights and environmental clauses in contracts, we also agree with suppliers on specific requirements for cooperation and information obligations in the event of human rights violations.
Our Code of Conduct for Business Partners also sets out fundamental expectations regarding respect for human rights. To monitor compliance with these principles and use the results to provide industry-wide support, Fresenius Kabi, for example, prepared to join the Pharmaceutical Supply Chain Initiative (PSCI) as an associate member in the reporting year (2024). In the future, the company will participate in the industry-wide audit pooling and thus contribute to greater transparency regarding working conditions and – where necessary – corresponding corrective or remedial measures in the pharmaceutical supply chain.
“Our membership in the Pharmaceutical Supply Chain Initiative reflects our commitment to shared responsibility, ethical sourcing, and collaboration — all essential to driving respect for human rights across our value chain.”
Marco Kraemer, Director Supplier Quality Management & Human Rights Function, Fresenius Kabi
To further increase transparency in our upstream and downstream processes, we also plan to further expand the existing descriptions and visualizations of our value chains and carry out focus risk analyses on this basis. Further details on preventive and remedial measures, as well as on appropriateness and effectiveness, are available here.
Human Rights at Fresenius
Our Human Rights ProgramContact
Fresenius SE & Co. KGaA
Else-Kröner-Str. 1
61352 Bad Homburg
Germany
humanrights@fresenius.com
Human Rights Program
Our Human Rights Program Group-wide Governance & Responsibilities Preventive & Remedial Action Grievance Procedure & HandlingWhistleblowing system
Reports on possible human rights or other types of compliance violations can be reported around the clock, either anonymously or by name, via our whistleblower system*:
Phone number: +49 (0) 800 181 1338*
https://freseniusgroup.ethicspoint.com
More infos about our grievance mechanism
*The prices of your mobile or landline contract apply
Operational implementation of the Human Rights Program is ensured through Group-wide governance and clear responsibilities within the business segments and at Group level. The Management Board oversees our Group-wide Human Rights Program. The Group function Risk & Integrity reports directly to the Board member responsible for Sustainability.
Within this Group function, the Group Human Rights Office is responsible for the Group-wide human rights due diligence approach, such as the Human Rights Risk Assessment methodology. It supports the business segments in implementing requirements that serve to fulfill their human rights due diligence obligations. In addition, the Group Human Rights Office monitors relevant legal and regulatory developments. It further chairs the Human Rights Council and exchanges with the Group's Risk Steering Committee.
Each business segment has appointed a Human Rights Function. This Human Rights Function is responsible for the operational implementation of the Group-wide human rights strategy within its own business segment. It reports to the Group Human Rights Office and its respective Board or Management.
We have appointed risk owners for relevant departments. As subject matter experts, the risk owners are responsible for appropriate risk management and the implementation of risk analyses in their area of responsibility – for example in Human Resources, Procurement, or Occupational Health and Safety.
The risk owners provide functional expertise for the risk evaluation and identification, analysis, prioritization, and management of risks. These tasks are fulfilled in collaboration with the respective risk management functions as well as with the business segment’s Human Rights Function to whom information is reported. This cross-functional exchange ensures a four-eye principle.
We have set up a Human Rights Council to promote the exchange of information on current human-rights-related initiatives and topics within the Fresenius Group. It is made up of representatives from various functions, such as Compliance, Sustainability, Communication, and Procurement, as well as the Human Rights Functions and the Group Human Rights Office.
The Human Rights Council meets quarterly. The meetings focus on the further implementation of the Human Rights Program, the ongoing development of reporting structures as well as increasing transparency along our value chains.
Review of risk management: effectiveness and appropriateness
The Group Human Rights Office supports the business segments and monitors their activities for implementing human rights due diligence. The appropriateness and effectiveness of these are monitored via the implemented processes, measures and corresponding documentation.
In addition, alongside the review by the Group Human Rights Office, internal controls are an integral part of Fresenius’ risk management. The internal control system (ICS) consists of a comprehensive set of internal controls and complementary processes. The results are incorporated into the regular review of the adequacy and effectiveness of our Human Rights Program.
We are continuously working to develop and expand the processes and procedures of our Human Rights Program. In addition, we test existing procedures as well as new approaches and concepts together with various participants. These include, for example, official advice centers for the implementation of human rights due diligence and specialized consulting firms.
Human Rights at Fresenius
Our Human Rights ProgramFurther Information
Risk Assessment & Impact Preventive & Remedial Action Grievance Procedure & HandlingContact
Fresenius SE & Co. KGaA
Else-Kröner-Str. 1
61352 Bad Homburg
Germany
humanrights@fresenius.com
Human Rights Program
Our Human Rights Program Risk Assessment & Impact Preventive & Remedial Action Grievance Procedure & HandlingWhistleblowing system
Reports on possible human rights or other types of compliance violations can be reported around the clock, either anonymously or by name, via our whistleblower system*:
Phone number: +49 (0) 800 181 1338*
https://freseniusgroup.ethicspoint.com
More infos about our grievance mechanism
*The prices of your mobile or landline contract apply
The expert committee is made up of four international specialists from the fields of science, business, and consulting. It was established by Michael Moser, member of the Management Board, and helps Fresenius to further develop its sustainability strategy. Yesterday’s meeting focused on key issues such as water management and the ongoing development of the Group-wide human rights program.
Sarah Tix, Head of Group Sustainability, and Anahita Thoms, co-chairs of the Advisory Board, took time out from a tour of the plant to explain the importance of sustainability issues - start the video on the right.
Fresenius Kabi’s Friedberg site supplies essential medical devices used in the care of critically and chronically ill patients in more than 100 countries. Around 650 employees work at the plant. Every year, more than 125 million infusion solutions and around 70 million liquid medicines such as analgesics and narcotic agents are manufactured here. The adjacent logistics center puts together around 40,000 consignments every month and is responsible for packing and shipping them.
March 26, 2025
Bad Homburg, Germany
Publication Annual Report 2024
Consolidated Financial Statements and Management Report (IFRS)
