As stipulated by the board of directors and executive board of the Sanitas Group, compliance plays a central role in careful and honest corporate management within the framework of voluntary commitment and corporate social responsibility aimed at social, economic and ecological sustainability.
With this in mind, the management team and staff of Sanitas are committed to ensuring complete integrity in all their actions, particularly with regard to the observation of laws, internal rules of conduct and the strictest ethical and moral standards as a central part of the corporate culture and a key principle of corporate business. The management team ensures that the directives deriving from these requirements are observed and, if necessary, implemented at all company levels. All members of staff of the Sanitas Group are expected to conform to these rules and act with integrity at all times (zero tolerance policy). In other words, every individual is responsible for compliance at Sanitas.
Structures and processes form the basis of an effective compliance management system and enable implementation of the principles outlined in the code of conduct. The structure and organisation of the compliance management system is designed to prevent illegal or irregular behaviour wherever possible or otherwise to detect and resolve any occurrence of such behaviour as quickly as possible.
Management bears overall organisational responsibility. The organisational structure is designed to avoid violations of laws and regulations with a reasonable amount of effort or otherwise to identify any cases as early as possible. The board of directors of the Sanitas Group bears overall responsibility for monitoring the compliance principles and guidelines and ensuring observance of these. The executive board of the Sanitas Group and the line organisation bear joint responsibility for operational implementation of the compliance guidelines. Within this framework, every board member and every employee is responsible for observing the compliance guidelines in their area of responsibility and influence. In other words, each individual is responsible for compliance in day-to-day business.
The compliance processes are the operational element of an effective compliance management system. They comprise systematic processes that are designed, on the one hand, to collect, assess and verify the information needed to ensure the compliance guidelines are met and, on the other, to outline the compliance support options available to employees. As part of the compliance management system, the compliance processes serve as a framework for organising the procedure and functionality with regard to the prevention, identification and adjustment/sanctioning of compliance violations. To this effect, the compliance processes are integrated into the business processes.
The Sanitas Group gives its employees responsibility not only for achieving the stipulated corporate goals but also for the way in which they do so. In doing so, the focus must not only be on the corporate success of Sanitas but also on the integrity and legal and policy conformity of its business practices with a view to protecting the company’s reputation. Incentives designed to guide the management team and staff are an effective way of implementing such business practices in line with the compliance guidelines. And any violation of the compliance regulations must be met without exception by the appropriate sanctions. Sanctions include the reduction of financial entitlements, warnings and ultimately termination of employment.
In supporting the implementation of compliance guidelines with appropriate incentives, commercial success must not be rewarded if this is associated with risks to compliance and the company’s reputation. It is also important to prevent staff from being misguided into the acceptance of risks to compliance and reputation as a result of unrealistic commercial goals. Company management must therefore ensure that the employee performance review process takes into account not only achievement of the stipulated commercial goals but also observance of the compliance guidelines.
As a means of prevention, the effectiveness of the Sanitas Group’s compliance management system is reviewed regularly and systematically. These checks focus on compliance with laws and guidelines, the level of knowledge and training of staff, and the process conformity of the business practices.
Alongside institutionalised controlling processes with regard to the effectiveness of the compliance management system in general and the integrity and compliance of business practices in particular, the Sanitas Group supports the development of a corporate culture based on integrity and compliance and depends, above all, on the initiative and individual responsibility of all members of staff.