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Basic Principles of Our Compliance Management System 

With our compliance management system that is valid worldwide, Sartorius ensures that the members of its individual boards, executives and employees comply with all legal regulations and codes, and perform their activities in accordance with the company’s internal rules and guidelines. Targeted training and awareness-raising prevent any misconduct, as well as economic damage and loss of image.

 

Sartorius makes every effort to ensure optimal risk management by using a combination of approaches: a preventive compliance approach designed to proactively stop any potential breaches before they occur and a repressive compliance approach intended to continuously monitor compliance with our rules. These processes are closely intermeshed, creating a standardized compliance management system that aims to offer the best possible protection against potential violations of our rules and regulations. 

 

Sartorius has developed a Code of Conduct as a preventive component of our compliance management system and has committed to an Anti-Corruption Code.

 

Sartorius Code of Conduct

The Sartorius Code of Conduct specifies the requirements on the responsible conduct of all employees of the Sartorius Group. This set of rules provides them with guidance on how to act in a legally correct and ethically appropriate way in their daily work. 

 

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Sartorius Anti-Corruption Code

This Anti-Corruption Code serves as the basis for making all employees aware of the risks of corruption, while providing guidance, instructions and help to enable them to take the appropriate action to prevent and fight such corruption. 

 

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Sartorius ensures that all Group employees worldwide are thoroughly familiar with both Codes by requiring them to complete online training and earn a certificate. 

Sartorius adheres to the principles of the United Nations Universal Declaration of Human Rights, the International Labor Organization (ILO) and the United Nations Global Compact, the world’s largest initiative for human rights, labor standards, environmental protection and anti-corruption. The company’s internal principles, such as its Code of Conduct and Code of Conduct for Suppliers, are derived from these global tenets.

In addition, Sartorius has made it a policy to require its business partners to adopt its standards of compliant conduct as well. For this reason, Sartorius performs third-party due diligence or so-called business partner checks; i.e., the company reviews the integrity of business partners on a risk-oriented basis. 

Code of Conduct for suppliers

The Sartorius Group also expects its suppliers and service providers, in particular, to comply with internationally recognized social and environmental standards, to abide by the laws, uphold the tenets of fair competition and to respect human rights. Our company excludes existing or new suppliers who are determined to be the source of considerable risks regarding compulsory, forced or child labor, other violations of human rights or negative effects on society. These requirements are set forth in our Code of Conduct for Suppliers and Service Providers.

 

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An internal system is available for reporting any suspicious circumstances involving potential compliance violations.

 

Whistleblower Portal

In addition to having set up established routes for reporting compliance-related concerns to the Compliance Department or managers, Sartorius has created a whistleblower portal to enable employees, suppliers, customers or partners to report any potentially damaging conduct 24 hours a day, seven days a week. This specially secured portal is made available through an external provider who is specialized in handling confidential data securely. Every whistleblower can decide whether or not to report compliance-related concerns by giving his or her name or by doing so anonymously.

 

Whistleblower Portal

Compliance Hotline

Sartorius employees, suppliers, customers or partners can use our telephone hotline to contact our Compliance Department directly. There they will receive answers to questions concerning compliance and can report damaging conduct, also anonymously, if desired. This hotline is available free of charge worldwide.

 

The repressive component of our compliance management system is designed to ensure comprehensive monitoring and efficiency review of the control mechanisms mentioned above. The key elements of Sartorius’ internal control system consist of a combination of process-integrated and process-independent monitoring measures. Among the most important organizational measures that have been anchored in Sartorius’ corporate culture for a long time is the rule of separation of functions, taking into account the “four-eyes” principle. In particular, the Supervisory Board and the Legal Affairs & Compliance Department play a key role in process-independent monitoring and review activities. Within the Supervisory Board, the Audit Committee, in particular, is tasked with reviewing internal control processes. In addition, this committee intensively focuses on reviewing the annual and consolidated financial statements and the quarterly financial reports. To ensure systematic, prompt identification of risks, Sartorius moreover has a monitoring system in place, pursuant to Section 91 II of the German Stock Corporation Law (AktG), for early group-wide detection of risks that have the potential to jeopardize the company’s continued existence.