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We operate in a highly regulated industry that requires strict compliance with laws, rules, standards and regulations that can be complex. Non-compliance may result in reputational damage and significant penalties for the company, the management or an employee.
Our Compliance Officers are authorised and obligated to receive information and complaints concerning violations against the Code of Conduct and/or Compliance Guidelines, to inform the Management, to process the violation together with the Management, to propose appropriate measures and to inform other authorities within the company, for example Internal Audit, the responsible Legal Department and the Group Compliance Office, which in turn shall inform the Board. The Group Compliance Office has to ensure the involvement of auditors to the extent necessary.
To ensure compliance, all employees of B. Braun are required to report any suspected potential violations of the Code of Conduct or the law. Appropriate communication channels have been established which are managed by the Compliance Officers. All reports of suspected non-compliance will be investigated appropriately, and corrective action will be taken as required to further enhance the Compliance Management System. The B. Braun Group prohibits any retaliation against an employee or third party for reporting a violation or suspected violation in good faith.
Notifications can be made to the Compliance Office in a number of ways. Post, telephone and e-mail are all possible methods (contact details). It is important that the following questions are answered in all notifications.
A notification must make it clear who the sender is. Only if the sender can be easily identified can an effective dialogue can be launched. An exception regarding anonymous notifications is explained at the end of these questions.
A notification must be formulated in a way that enables the facts on which the notification is based to be determined. Please note that the Compliance Officers rely on receiving the full facts of each case. Further information may also be required, which is why it is often helpful if you do not submit your notification anonymously, as this will enable further enquiries to be made. For information about what content is not appropriate in a notification, see „What issues must not be notified via the whistleblower system“.
It is important to specify exactly when the events described took place so that responsibilities and other facts relating to the case can be assigned appropriately. The notification should be made promptly (generally speaking, within a few days). There is little that can be done about incidents that took place a long time ago.
The place from which the notification is being made should be specified as precisely as possible; please state the relevant country, location, plant, division and department wherever possible.
Anonymous notifications deviate from the pattern described above. To make your notification anonymous, please submit it via an e-mail account which prevents you being personally identified, for example, from an address you yourself have set up under a pseudonym; this is easy to do using private e-mail services. When composing the notification, you should focus on the question of WHAT (see Point 2 above). All details you give in relation to places and times must be carefully selected to make it difficult or impossible to identify you. However, further enquiries may still be necessary, so we ask that you continue to check the anonymous e-mail account regularly so the anonymous contact can be kept up. We guarantee that all data and personal rights regarding notifications made via the whistleblower system will be protected to the highest possible degree. Many thanks in advance for your support!
The whistleblower system serves to clarify issues relating to compliance and B. Braun‘s Code of Conduct. If an individual were to use it to make allegations or complaints against one of our employees for personal or political reasons, this would represent an abuse of the system. We may take action in the event of such abuse.
Dr. Volker Daum
Group Compliance Policy Officer
B. Braun SE Group Compliance Office