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Compliance is generally understood as a management-level responsibility, aimed at ensuring adherence to legal requirements and internal policies.
Compliance is a high priority at UKB. However, it does not only apply to the management. Rather, each individual employee is responsible for observing the current laws and regulations, and adhering to the Compliance Management System of the hospital. In this regard, UKB follows the principles of the Public Corporate Governance Codex of North Rhine-Westphalia, according to which the management is responsible for ensuring compliance adherence to statutory provisions and internal company guidelines, and for promoting their observance within the organization.
Following this principle, the Department of Internal Audit & Compliance supports the Executive Board in implementing and further developing UKB's Compliance Management System. It offers its assistance to managers and employees in compliance concerns and is the contact reference for anti-corruption issues. The Department primaly focuses on corruption risks, whereas other operational units partly address further compliance risks such as, for example, risks connected to data security.
In accordance with the German Supply Chain Risk Management Act (“LkSG”), UKB´s Executive Board has appointed the Department with monitoring and reporting on the adherence to the LkSG´s risk management regulations. The procedures established by LkSG for daily business operations are primarily implemented by the purchasing department of the hospital, which conducts contract negotiations and concludes supplier agreements. Nevertheless, all employees at UKB share the same responsibility for complying with human rights and environmental regulations (see the Policy Statement of the Executive Board).
The department also assumes an internal reporting function, which extends to the whole UKB group (UKB and its subsidiaries), as defined by the German Whistleblower Act and the EU Whistleblower Directive. In the event of a suspected criminal act, a law violation, or a violation of an internal company regulation, Mr. Andreas Heiden (t. 0228 / 287- 13563), the Head of Department and the designated Compliance Officer, is available for consultations on weekdays between 9 am and 4 pm. Other Department employees can be contacted as well. Please report to the Department in cases of human rights violations, environmental risks, and German Supply Chain Act infringements. The Department´s Whistleblower Portal can be used for reporting, as well. Please consult the current Data Protection Policy for more information about internal privacy regulations.
Internal directives at UKB
By acting loyally and integrally, you as an employee also play an important role in preventing misconduct and averting damage to the hospital. Please consult UKB´s regulations for additional information.
The Code of Conduct adopted by the Executive Board forms the orientation framework within the Compliance Management System at UKB. It defines the requirements for complying with the law regulations on the one hand, and for acting with integrity on the other.
The Anti-Corruption Guidelines* of UKB illustrate the correct procedures and provide instructions for cases of doubt on the one side, and aids for practical decision-making on the other. This document aims at reducing uncertainties and risks for all employees. At the same time, not everything is prohibited per se. It is important that UKB´s employees are able to correctly assess the criticality of a given situation and to behave accordingly.
Due to the integration of patient care, research activity and medical training, the human contact at a hospital is unavoidable. Possible corruption-relevant aspects can be found in everyday life more often than one might think. For example, when being in contact with patients, it might be questioned to what extent cash donations* are appropriate; or, during the Holidays´ Season, it might be contemplated if gifts* by business partners are permitted. Moreover, UKB has internal regulations for reimbursement of hospitality events and sideline activities.
* The document is currently only available in German. An English translation will be provided as part of the next revision.