As a global healthcare company, Fresenius views respect for human rights as an integral part of our responsibility. Human rights areas of particular concern to the Group include, for example, working conditions at our own sites and in the supply chain.

Our goals and ambitions

Fresenius is committed to respecting human rights. Our Group-wide ambition is to regularly analyze human rights impacts, prevent violations, minimize risks, and take necessary remedial action in the event of violations – in our supply chain and in our own companies, as well as in connection with our products and services.

Our approach

Medical care for patients and the well-being of our more than 190,000 employees are among the most important engagement areas of our human rights due diligence. Our commitment to human rights extends beyond our own company operations and core business. In line with our human rights due diligence program (Human Rights Program), we take human rights aspects into account when selecting and cooperating with our suppliers and business partners, too. We expect them, among other requirements, to respect human rights in their value chain as well. We specify and communicate these expectations in our Code of Conduct for Business Partners. Further details on our Human Rights Program can be found here.

We are constantly working on increasing the transparency of our supply chains. The knowledge gained by doing so helps us to ensure secure supplies while addressing human rights risks in the procurement of important raw materials and supplies.

Organization and responsibilities

The Group Management Board oversees our Group-wide Human Rights Program. The Group function Risk & Integrity reports directly to the Group Management Board member responsible for Legal, Compliance, Risk Management, ESG, Human Resources and the business segment Fresenius Vamed. Within this Group function, the Group Human Rights Office established in 2023 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 fullfil their human rights due diligence obligations.

Operational implementation is ensured through Group-wide governance and clear responsibilities within the business segments and at Group level:

The members of the Group Human Rights Office, besides the Human Rights functions, participate in the Human Rights Council with other persons from specialist departments of the business segments. It meets quarterly and is the advisory body to the Group Human Rights Office. The approximately 20 members of the Human Rights Council are active in various functions within the Group, including compliance, legal, sustainability, communication, and procurement, and thus cover the many perspectives of the topic. The participants discuss Group-wide initiatives and present new concepts and methods. The four meetings in the reporting year focused on the further implementation of the Human Rights Program, the development of support materials for carrying out risk analysis, measures in the business segments, and the presentation of a guidance document for dealing with human rights violations.

Reports on the Human Rights Program are submitted to the Group Management Board and other bodies at least once a year and on an ad hoc basis. In 2023, this included, e. g., the results of the risk analysis as well as reporting on the status of the implementation of the Human Rights Program.

For further information on possible risks relevant to human rights, please refer to the Opportunities and Risk Report, to the Group Non-financial Report in the Compliance section, or to the report submitted to the Federal Office for Economic Affairs and Export Control (Bundesamt für Wirtschaft und Ausfuhrkontrolle, BAFA) on the LkSG. The publication of the BAFA report is planned for the first half of 2024.

Guidelines and regulations

Our Human Rights Statement adopted by the Group Management Board is based on the United Nations Guiding Principles on Business and Human Rights (UNGP) and relevant internationally recognized human rights standards and frameworks, as set out in the Human Rights Statement.

It covers our fundamental principles on human rights as a commitment for the Fresenius Group. It includes, among other things, that we do not tolerate any use of force, threat of force, or other forms of coercion. We strictly prohibit the use, support, or toleration of exploitative, child, or forced labor. Discrimination must be prevented, equal opportunities promoted, and safe working conditions created. We position ourselves on various topics both with regard to Fresenius’ employees and with regard to our suppliers.

A revised version of the Human Rights Statement was published in 2023 and reflects the requirements of the LkSG. We update it on the basis of the human rights focus topics that we identify, e. g. as part of the risk analysis. A revised Human Rights Declaration will be published in 2024.

Where applicable, topics such as the handling of conflict minerals, developing technologies, or ethical issues in research, development, and clinical studies are prepared and considered by the business segments or specialist areas concerned.

Before the EU Conflict Minerals Regulation came into force, we already addressed this relevant topic. We do not purchase conflict minerals directly. However, it cannot be completely ruled out that they have been processed in components and semifinished products that we purchase and further process or use in our products. In this case, the relevant Group and business segment Codes of Conduct for dealing with suppliers and other business partners apply. In the reporting year 2023, no violation of the applicable requirements was detected.

Our Codes of Conduct for Business Partners and Suppliers take into account the respective business models of the business segments. The Codes of Conduct are used in purchasing contracts and contracts with other business partners, e. g., distributors and sales representatives – as annexes or references. Explicit human rights and environmental clauses are also included in contracts on a risk basis.

Furthermore, in the reporting year 2023, a Social & Labour Standards Policy was adopted. This sets minimum social standards for the entire Group and specifies the content of our Code of Conduct. Further details can be found in the Employees chapter.

Human Rights Program

Through our Human Rights Program, we establish preventive measures helping Fresenius to identify and address human rights risks in its business processes and include human rights risks in our Group-wide risk management. An important component of risk management, as explained in the Annual Report, are internal controls. Findings from the processes of the internal control system (ICS) will be incorporated into the regular review of our Human Rights Program for appropriateness and effectiveness.

Human rights risk management and assessment

The Fresenius Group has identified human rights areas and fields of action in all business segments that are particularly relevant to our value chains. In doing so, we consider various factors, including business models of the business segments, and current public debates and regulatory developments such as the LkSG. A Group-wide standard operating procedure (gSOP) defines a framework for human rights risk management. It describes the pillars of the Human Rights Program at Fresenius and contains explanations on responsibilities, the performance of risk analyses, the handling of human rights risks in our own business and the supply chain, the documentation of measures, and reporting.

Our Human Rights Risk Assessment methodology is integrated into our Group-wide risk management. We consider potential risks based on country-, industry- and business-segment-specific aspects. We assess them based on their potential impact and likelihood. This also takes into account what influence we as a company have on the probability of the risk occurring. Building on our assessment we define preventive and, if necessary, remedial measures. The responsible functions in the business segments are closely involved in carrying out risk analyses. In addition to the annual risk analysis, we also conduct event-related risk analyses.

In 2023, a total of 939 multi-step risk analyses were conducted on human rights risks within the Fresenius Group. Where necessary, we use the results to adjust processes.

We are continuously developing the processes of human rights risk assessment, e. g., by adapting it to regulatory requirements such as the LkSG or by optimizing internal department-specific processes. If we suspect human rights to be violated, we respond accordingly. In the reporting year, we established a Remediation Toolbox. This handout is intended to support our business segments in dealing with human rights violations.For more information on opportunities and risks, please refer to the Opportunities and Risk Report.

Complaint mechanisms and reporting channels

To make it as easy as possible for potentially affected people, we offer internal and external reporting systems. Employees of the Fresenius Group as well as external stakeholders – including those in the supply chain – can submit their information via existing reporting systems or use designated email addresses to draw attention to possible human rights and environmental violations, along with others.

In the reporting year, we received reports via the existing reporting channels, which we also examined for human rights aspects.

All information is processed by specially trained staff within a team of experts. Depending on the circumstances, it may be necessary for us to involve other specialist departments to clarify an incident. More information on our reporting channels and how we are dealing with potential compliance violations can be found in the Compliance section and in the Data protection section.

Human rights training

Human rights areas are addressed in different training sessions throughout the Fresenius Group. For example, mandatory training for employees on the respective Code of Conduct includes human rights aspects. Additionally, in 2023, 61 training sessions were held on the Human Rights Program, risk analysis, dealing with human rights violations, and human rights due diligence. In addition to the central contact persons for human rights activities in the business segments, these training sessions were also directed at other persons from specialist departments.

In addition, we developed a human rights training course in the reporting year 2023, which will be gradually rolled out globally from 2024.

Supplier evaluation

Transparency in our supply chains is important to us, for example, to identify and address human rights risks. Additional information on procurement activities can be found in the Group Management Report.

We expect our suppliers to comply with applicable laws as well as ethical standards of conduct in their day-to-day operations. We conduct risk-based business partner reviews before entering into new business relationships. If high risks are identified based on risk analysis results or the business partner due diligence, we contact the supplier and evaluate the situation in more detail using another questionnaire on a risk-based approach.

Based on the risk analyses results, we initiate preventive measures where necessary. Information on risk analysis and prioritized risks in the supply chain can be found in the section Human rights risk management and assessment above in this chapter. If we become aware of a human rights violation in our supply chain, the goal is to take remedial action and avoid a future violation in our business operations.

In the Fresenius Group, we maintained business relationships with more than 58,000 suppliers in 2023. Currently we do not collect data on the proportion of spend with local suppliers at Group level.