Anti-Corruption and Anti-Bribery Policy

1. Prohibition

It is prohibited to offer, promise or grant an undue advantage to a public official or to a person in the private sector, either directly or through third parties, in order to influence a decision. It is likewise prohibited to demand or accept such an advantage.

The prohibition also covers payments to speed up routine official acts (facilitation payments).

2. Gifts and invitations

• Permitted only if they are of low value, socially customary and made openly.
• Cash and cash-equivalent benefits are prohibited without exception.
• Benefits to public officials and to persons with procurement responsibility in the healthcare sector require the prior written approval of Executive Management.
• Every approved benefit is documented with occasion, recipient and value.

3. Sponsoring and donations

Sponsoring and donations are permitted only if the recipient and the intended use are known and documented and no consideration in the form of a purchasing decision is expected. We do not make donations to political parties.

4. Intermediaries and commercial agents

Intermediaries are screened before a contract is concluded. Their remuneration must be reasonably proportionate to the service rendered and must be agreed in writing. Success fees without a verifiable service are not agreed.

5. Records

All payments are recorded completely and truthfully in the accounts. Concealed accounts, off-the-books cash funds or incorrectly described entries are prohibited.