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The Management of each B. Braun Group Company is responsible for establishing, maintaining and continually improving a local Compliance Program, in accordance with company requirements of the Group Compliance Officer (and any local jurisdictional rules and regulations applicable to them).
The Compliance Program includes the appointment of a Compliance Officer, at times supported by a should include a local Compliance Committee, the dissemination and training on the Code of Conduct, continuous monitoring of the company’s compliance status, regular and periodic written status reports, and the creation of reporting channels to encourage employees and third parties to report any suspected violations of the Code of Conduct or suspected violations of law.
The B. Braun Companies perceive compliance as a management task, supported by an integrated reporting structure. In this respect, management regularly coordinates with the responsible (deputy) Compliance Officer, who shall involve the Group Compliance Office where required.
The Group Compliance Office is an organisational unit that reports directly to the Board of the B. Braun SE and has the responsibility of performing supervision and consultation functions. At a functional level and for matters requiring approval, it reports directly to the CEO of the B. Braun SE. The Group Compliance Office is headed jointly by the Group Compliance Policy Officer (Dr. Volker Daum), who is internally responsible for the regulations (norms including creation and ongoing development of Compliance Guidelines, consultancy, and training), and the Group Compliance Organisation Officer (Thomas Klabunde), who is internally responsible for enforcement matters (organisation structure and implementation monitoring). The Group Compliance Office is responsible for the execution and ongoing development of the Compliance Management System.
At least once a year, the Group Compliance Office, supported by the Group Compliance Committee, reports in detail to the whole Board and assists the whole Board in the preparation of reports for the Audit Committee of the Supervisory Board as well as in the preparation of the annual Compliance Report.
The Compliance Officers act as interfaces between the Group Compliance Office and the management and/or employees of their respective companies. The Group Compliance Office ensures, by conclusion of an official letter of appointment, that each B. Braun Company nominates a Compliance Officer who then informs by reports or otherwise to the Group Compliance Office on compliance-relevant issues.