Compliance

For RHÖN-KLINIKUM AG, by contrast, compliance has been a key subject already since 2008. Above and beyond the statutory requirements of compliance, a Group-wide Compliance Management System (CMS) was set up. It is pursuing the aim of ensuring that statutory requirements and ethical codes of conduct are observed over all hierarchical levels. 

Compliance is to everyone’s advantage: it protects employees as well as persons holding organisational responsibilities from civil and criminal legal action, and contributes to a release from liability. Compliance safeguards efficiency because punitive payments and litigation costs are prevented and pecuniary losses from white-collar crimes are counteracted. Compliance also protects against negative media coverage. Compliant organisational structures enable employees to better identify themselves with the company and further improve corporate culture when employees know that they are protected against compliance breaches and that the compliance officers will be there to support them in critical situations. The positive external effect of a duly compliant company also reflects well on the employees.

The establishment and functioning of the CMS governs the Rules of Procedure for Compliance, which are binding on each and every employee. The chairman of the Board of Management of RHÖN-KLINIKUM AG holds primary responsibility for compliance. He reports to a committee of the Supervisory Board. Given the high importance of this subject, the Supervisory Board Committee for Compliance and Communication meets at least on a quarterly basis. Within the scope of their compliance-related duties, the individual subsidiaries are assisted by the Group’s central compliance organisation. On site, it is the compliance officers who report to the central compliance organisation and act as contacts on site. To ensure smooth coordination between risk management, the Internal Auditing Department and compliance, there is also a Compliance Committee that meets on a regular basis. 

We conduct a regular review based on internal and external events of how effective and up-to-date the CMS is, continuously adjusting our rules as required. Since the corporate restructuring in 2014, we have been above all concerned with ensuring that compliance breaches are prevented from the outset, i.e. with identifying and averting risks in time. Key measures consist in reviewing workflows ensuring legally compliant work activity (audits) and adjusting them as required, as well as informing employees of rules to be complied with. In addition to a guide to the most important questions on the subject of compliance, we have developed a recommended procedure for dealing with potentially critical contracts. In this way situations that might give rise to corruption, and thus allegations of corruption, can be prevented proactively.

In the future, the head of Compliance will continue to focus particular efforts towards creating awareness. At RHÖN-KLINIKUM AG, information policy enjoys very high priority, whether as part of internal higher-qualification measures or work on corporate bodies. In 2015 at least two training courses were held at each site, one for the medical doctors and one for the nursing staff. They covered the compliance risks typical for these areas and were oriented in their subject matter to the group of participants. In Bad Neustadt, each new employee now attends a compliance training course. The selection of subjects in the past year related e.g. to use of patient data, anti-corruption and invoicing of foreign patients. Moreover, special services agreements were discussed in separate training courses. This was complemented by further events involving small groups on specific subjects for managing directors or boards and panels.

Our actions for the well-being of patients are oriented by the corporate principle “Don’t do to others what you would not like done to yourself, and don’t leave off doing anything that you would like done to yourself.” This corporate principle in the sense of compliance is an obligation in all our decision-making processes. To achieve our corporate objectives, we do not just meet the legal regulations but go above and beyond them with our own internal requirements. These internal rules are based on even more stringent ethical standards. They can be found in the form of Group works council agreements, the Rules of Procedure for Compliance as well as guidelines and recommendations (e.g. code of conduct) so that every employee is enabled to pursue our corporate objective in accordance with our values.