Compliance

At Fresenius, compliance with national and international legal and ethical principles is an integral part of our corporate culture. These principles, which underpin our professionalism, include honesty and integrity in relations with our patients, customers, suppliers, governments, employees, shareholders, and the general public. We make every effort to ensure that our employees know and comply with the relevant national and international rules.

The Fresenius Code of Conduct contains the key principles and rules for conduct within the Company and in relations with external partners and the public. They are embodied in Company guidelines and procedures. The principles may not be undermined by individual directives and instructions and must be heeded in business relations of any kind. Their purpose is to help our employees make the right decisions in their day-to-day work. The Fresenius Code of Conduct serves as the model for the adoption and further elaboration of proprietary codes of conduct within all the business segments. As a rule, this does not affect the compliance programs already in place if they do not conflict with the spirit and intent of the principles of the Fresenius Code of Conduct. The Code's principles and rules apply globally – through the compliance programs and the codes of the business segments – to all employees of the Fresenius Group. We organize training programs to instruct our employees on the applicable legal requirements and internal company guidelines. Management superiors and compliance officers at the Group level and within the business segments support and advise our employees on implementing and applying these rules. By complying with the laws and observing the principles and rules of the Fresenius Code of Conduct, every employee makes his or her contribution toward ensuring that Fresenius is perceived as an honest and reliable partner in the health care sector for patients, customers, suppliers, governments, and the public.

We have published the Fresenius Code of Conduct on our website at www.fresenius.com (see Who we are - Corporate Governance).

At Fresenius, compliance is generally regarded as a management task on all decision levels. As a corporate governance function, the Corporate Compliance division reports to the Chief Compliance Officer, the member of the Management Board responsible for Legal Affairs, Compliance, and Human Resources. The division supports the Chief Compliance Officer in establishing and implementing guidelines and procedures which shall ensure that both the applicable statutory requirements and the requirements of the Fresenius compliance program are adhered to.

Compliance activities and guidelines have been implemented in each business segment and a chief compliance officer has been appointed who is responsible for communicating information and for introducing, elaborating, and monitoring the compliance procedures in the respective business segments. He is supported by additional compliance officers appointed on the basis of the organizational and business structures. The employees of the Corporate Compliance departments support and advise the compliance officers at the business segment, regional, and country levels so as to ensure uniform application of high ethical standards throughout the Company and strict adherence to our values, applicable local and international laws and regulations, and the Company's guidelines and procedures.

An internal reporting system and individual audits by the Internal Audit division help to monitor and ensure adherence to legal requirements and compliance standards. The Internal Audit division conducts audits at the companies and in the business segments worldwide. Within the scope of their audit assignment, the auditors have unrestricted authority to demand information and inspect records at the audited companies.

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