Zu den Inhalten springen

Supply Chain Due Diligence Act

With the Supply Chain Due Diligence Act (LKSG), the University Medical Center Freiburg, as an institution with at least 3,000 employees, has been legally obliged since 1 January 2023 to take human rights and environmental concerns into account and formalize them even more strongly in its supply chains than was previously the case.

Protecting people and the environment

The creation of decent work, healthy corporate growth and the sustainable use of resources are very important to the University Medical Center Freiburg. With the implementation of the LKSG, it is committed to keeping a closer eye on economic, ecological and social concerns. Its efforts are geared towards ensuring that human rights and environmental obligations are also protected and promoted in its supply chains.

Declaration of Principles of the University Medical Center Freiburg

The Executive Board of the Freiburg University Medical Center - a public corporation - issues the following declaration of principles on the basis of Section 6 (2) of the Act on Corporate Due Diligence in Supply Chains (LkSG), adopted on March 6, 2024:

The University Medical Center Freiburg is committed to respecting human rights and protecting the environment. It is the declared aim of the company management to respect, protect and promote human rights and the environment along the entire value chain. Violations of internationally enshrined human rights and national and international environmental protection regulations are not tolerated. The following international regulations, to which the University Medical Center Freiburg is committed, form the basis of the human rights and environmental due diligence obligations:

  • International Bill of Human Rights
  • United Nations Guiding Principles on Business and Human Rights (ILO) with their five basic principles: Freedom of association and the right to collective bargaining, elimination of forced labor, abolition of child labor, prohibition of discrimination in respect of employment and occupation, and occupational health and safety
  • UN Global Compact
  • OECD Guidelines for Multinational Enterprises
  • Core labor standards of the International Labor Organization
  • United Nations Convention on the Rights of the Child

The principles of the human rights and environmental strategy set out in this declaration apply to the entire business area of the University Medical Center Freiburg, including its subsidiaries, and must be observed by the management and employees in the performance of their assigned tasks. The University Medical Center Freiburg expects all business partners to comply with human rights and environmental obligations. Respecting and upholding human rights and environmental obligations is the basic prerequisite for cooperation with the University Medical Center Freiburg.

Overall responsibility for our human rights and environmental due diligence lies with the Executive Board of the University Medical Center Freiburg. In the subsidiaries over which the University Medical Center Freiburg exercises a controlling influence, responsibility lies with the respective management teams. However, the University Medical Center actively works to ensure that the due diligence obligations are implemented by them.

Responsibility for the operational implementation of the human rights and environmental due diligence obligations lies with the respective management of the organizational units that are involved in the implementation steps, in particular the procurement departments. The central coordination office is responsible for the downstream management and monitoring of the implementation of the due diligence obligations.

Identifying, weighting and prioritizing risks

The Freiburg University Medical Center conducts comprehensive risk analyses with regard to compliance with human rights and environmental obligations within its own business area and with its direct suppliers. The focus is on the following groups of people who are particularly at risk:
- Patients and test subjects
- Our own employees and third parties at the University Hospital
- Employees of suppliers

The use of technical solutions supports us in identifying, verifying, weighting and prioritizing risks. Our risk analysis system enables us to determine the individual risks of each business partner. Based on general supplier information - in particular country of origin and industry - an abstract risk analysis is carried out based on a large number of recognized indices and studies by external experts. On the basis of supplier self-assessments, an AI-driven media analysis tool, verified certifications and our own findings from inspections or business processes, we then check business partners for specific human rights or environmental risks. This not only takes into account the business partner's country of origin and sector. We also analyse product risks, trade level risks, the complexity of upstream supply chains and a wide range of other data in order to narrow down, localize and identify risks at an early stage.

We weight and prioritize risks by comparing the typically expected severity of a potential infringement and its irreversibility with the probability of occurrence. We also take into account our own possible contributions to causation and the degree of our influence in order to prioritize risks and take targeted action where there is a threat of risks materializing. We use a risk matrix to identify our need for action and initiate preventive and remedial measures where they are necessary.

Central coordination office

The University Medical Center Freiburg has established a central office to coordinate the measures for fulfilling due diligence obligations, which acts as a link between the organizational units and the Executive Board.

The central coordination office advises the relevant organizational units and is the first point of contact for questions and information on violations of due diligence obligations. It also monitors the implementation of the due diligence obligations.

Follow up on information (complaints procedure)

In addition to continuous and event-driven risk identification and assessment, all employees, external partners and third parties have access to a functioning complaints procedure. This web-based, multilingual whistleblower system complements the already established internal and external communication channels and is managed by the central coordination office.

This central communication channel can be used to submit or ask anonymous or confidential information and questions about compliance with the University Medical Center Freiburg's human rights and environmental due diligence obligations.

Every complaint triggers an evaluation process. If actual, verifiable violations can be identified, consistent steps or remedial measures are initiated in order to avoid the violations in the future or to bring about appropriate redress, at the end of which the reported violation is ended or an identified risk is minimized. Furthermore, all reports of potential violations and inquiries are examined to determine whether our existing processes and regulations can be adapted or improved.

Documentation and reporting

The implementation of all due diligence obligations is documented on an ongoing basis. We use a central risk management system to network all the information available to us on identified risks and the preventive and remedial measures taken.

We are also committed to transparent communication on the human rights and environmental challenges to which the University Medical Center Freiburg is exposed. Through our public reporting, we communicate identified risks, measures taken and progress made at least once a year.

Preventive measures

An internal company code of conduct applies in our own division, which clearly and comprehensibly summarizes the expectations and rights of employees.

The University Medical Center Freiburg offers extensive training and educational opportunities that employees can take advantage of. The employees entrusted with the implementation of human rights and environmental due diligence obligations regularly take part in further training measures in order to be able to implement the international requirements for human rights and environmental protection throughout the entire supply chain. We offer our business partners training and further education opportunities so that they too are empowered to promote human rights and environmental protection in their business activities.

Complaints management system

Anyone can submit information on human rights and/or environmental risks or violations. We provide an electronic system for this purpose. You can access this system by clicking on the link.

Click here for the complaints management system.

Report on the Supply Chain Act

Here you can find the report on the Supply Chain Act 2023.

Contact us

The implementation of preventive and remedial measures and the notification procedure are coordinated and supervised at a central office at the University Medical Center Freiburg.

If you have any questions or comments on the human rights and environmental due diligence obligations, you can contact the coordination office in the following ways:

compliance@uniklinik-freiburg.de
Phone: 0761 270-21366

University Medical Center Freiburg

Hugstetter Straße 55
79106 Freiburg
Phone: 0761 270-0
info@uniklinik-freiburg.de