Every aspect of opseo ESG policies is focused on achieving and upholding the opseo fundamental principles, which are both the foundation and the vision upon which we seek to realize our responsible business objectives: 1/ people 2/ performance 3/ purpose.

Both our principles and our policies are anchored in internationally recognized standards. opseo endorses the UN Guiding Principles on Business and Human Rights and applies them throughout its business operations and processes. In line with opseo’s fundamental principles, we base our human rights commitment on the International Bill of Human Rights consisting of the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, and the International Covenant on Economic, Social and Cultural Rights, as well as the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work. We support the OECD Guidelines for Multinational Enterprises and the resulting commitments to compliance with applicable laws, and to fighting corruption in all its forms. The same approach is reflected in our third-party procurement policy.

The policy applies to all directors, managers, and employees of the opseo Group (i.e., trainees, temporary staff and other employees who are deemed to be employees under applicable labor law and/or tax regulations) and all contractually bound representatives.

opseo commits to comply with applicable laws and regulations wherever it operates. Should there be any conflict between individual legal requirements and the requirements of this policy, opseo employees will comply with applicable laws and attempt to find appropriate ways to comply with the requirements of this policy. In the event of a conflict, opseo employees can contact the central legal department. To this end, opseo makes it possible to respond to confidential questions and to its employees’ concerns regarding ethics, compliance, or other requirements of the policy. opseo provides a whistleblower system to enable anonymous reporting of any suspicion of inappropriate, unethical or illegal conduct by another employee.

opseo will take appropriate disciplinary action for breaches of the code or other misconduct, which in the most serious cases may include consequences under labor law and possible legal action.

You can gladly contact us regarding any aspect of our ESG guidelines: recht@opseo.de

Avoiding conflicts of interest

A conflict of interest occurs when employees are involved in personal activities or relationships that make it difficult for them to do their job objectively and effectively.

Conflicts of interest may arise from:

  • Personal relationships
  • Outside engagements
  • Financial or business interests outside opseo

By avoiding conflicts of interest, opseo maintains its integrity and the trust that partners, patients/clients and suppliers place in it.

Working conditions and human rights

Child labor and young workers

All employees of the opseo group are of an appropriate age.

Under no circumstances will opseo employ individuals under the age of 15 or under the local legal minimum age for work or of mandatory school age, whichever is higher. When young workers are employed, insofar as short-term internships and work that forms part of an educational program are permitted, they must not be required or allowed by opseo to do work that is mentally, physically, socially, or morally dangerous or harmful or interferes with their schooling by depriving them of the opportunity to attend school.

Remuneration and benefits

All employees of the opseo group are paid fair and equal wages.

Remuneration – all opseo employees are provided with an overall remuneration package that includes salaries, individual bonuses, overtime pay, paid leave, holiday allowances, and other benefits which meets or exceeds the legal minimum standards or appropriate prevailing standards, whichever is higher. Other than legally mandated deductions, all other deductions from wages require the express and written consent of the employee. opseo offers a permanent contract with a competitive base salary, individual bonuses and an overall transparent financial model. opseo is absolutely transparent about the costs for employment and the revenue generated.

Benefits – opseo highly values the capabilities of its workforce, which is why we developed an infrastructure to support all our employees in their personal and professional growth. opseo supports staff at every stage of their careers by providing training and coaching courses.

Working hours

The working hours of all employees of the opseo group are reasonable.

opseo complies with applicable labor laws. The remuneration paid to employees complies with all applicable laws on wages and salaries, including the stipulations on minimum wages, overtime, legally established benefits, working hours, and paid leave. All overtime will be on a voluntary basis.

Modern slavery

All opseo Group employees work of their own volition. Under no circumstances will anyone at opseo use forced labor or permit such to be used, be it in the form of compulsory or trafficked labor, indentured labor, bonded labor, or other forms. Mental and physical coercion, slavery and human trafficking are prohibited and opseo practices zero tolerance on forced labor. Work at opseo is conducted on the basis of freely agreed and documented terms of employment. All opseo employees, both permanent and casual, receive employment documents that are freely agreed, readily comprehensible, and which respect their legal and contractual rights. opseo ensures that all employees have entered into an employment relationship that was not directly or indirectly dependent on a placement fee or other associated costs, as envisaged in the International Labor Organization standards.

Freedom of association and collective bargaining

opseo respects employees’ rights to form and/or join a legally recognized trade union of their choice or any other body representing their collective interests. opseo engages in constructive dialog and negotiates in good faith with trade unions or representative bodies on employment conditions, labor relations, and matters of mutual concern, to the extent practicable under national laws.

Harassment and non-discrimination

All employees of the opseo Group and are treated equally and with respect and dignity. Without discrimination on grounds of race, ethnicity, age, role, gender, gender identity, color, religion, country of origin, sexual orientation, marital status, pregnancy, dependents, disability, social class, trade union membership, or political views. This covers hiring, employment, remuneration, firing, promotion, reward and social benefits, training, disciplinary measures, termination, or retirement, all of which must be based on merit. No employee may be subjected to any physical, sexual, psychological, or verbal harassment, abuse, or other form of intimidation. In particular, attention is paid to the rights of employees most vulnerable to discrimination. opseo employees must not engage in any indirect behavior which could be construed as sexual or other harassment or bullying, such as making offensive or sexually explicit jokes or insults, displaying, emailing, texting, or otherwise distributing offensive material or material of a sexually explicit nature, misusing personal information, creating a hostile or intimidating environment, isolating or not co-operating with a colleague, or spreading malicious or insulting rumors. opseo employees will not be intimidated or harassed in the exercise of their right to join or refrain from joining any organization.

Health and safety

opseo is committed to providing healthy and safe working conditions.

Safety at work is accorded the highest priority. We ensure safe and hygienic working conditions that comply with the applicable legal requirements in the field of occupational health and safety. Appropriate measures to reduce the risk of accidents and improve working conditions are our goal. Each individual employee should be aware of the applicable laws, regulations, and internal company HSE guidelines. Work shall be organized such as to ensure that the necessary statutory breaks are taken to protect employees’ safety and health.

Corporate ethics

Corruption, extortion, and bribery

opseo supports the global efforts to fight corruption, extortion, and bribery.

opseo’s commitment to doing business with integrity requires consistently high global standards. opseo takes a zero-tolerance approach towards bribery and corruption; this applies to all opseo operations, regardless of local business practices, and prohibits both public and commercial bribery (e.g. to or from any third party). When in doubt, an opseo employee is expected to convey any concerns to opseo management.

No form of bribery and corruption will be tolerated and may lead to disciplinary action.

Privacy

opseo respects the privacy of all individuals, including employees and patients/clients, and their personal data, including digital information opseo holds about them.

At opseo, personal data is handled appropriately and in accordance with the law. The protection of patient and business-related data, in particular the strict adherence to patient or insured person confidentiality and compliance with the relevant data protection regulations, are essential foundations of our actions.

Confidential information and patient and business records must be protected from the view of third parties and employees who are not involved, be it in relation to patients, private or business partners or to our employees themselves. Similarly, such information and data must not be made available to third parties or employees not involved in the process. Personal data may only be collected, processed and used to the extent that this is necessary for tasks to be duly fulfilled and as per the statutory provisions.

Data and information security breaches must be reported immediately to the opseo Group’s data privacy officer.

Financial responsibility (accurate records)

The financial reports and other information that opseo maintains internally and the financial information it provides to shareholders, regulators and other stakeholders must be accurate and complete. opseo records provide valuable information for the business and evidence of opseo actions, decisions, and obligations. Procedures and processes must be in place to ensure that underlying transactions are properly authorized and accurately recorded. Any failure to record transactions accurately or falsifying or creating misleading information or influencing others to do so, could constitute fraud and result in fines or penalties for employees or for opseo. opseo records all transactions accurately, completely, and promptly; it only performs transactions, such as buying, selling or transferring services and goods, for which it is authorized. opseo ensures transactions are legally approved and based on valid documentation. The Finance & Controlling section has measures in place to avoid any potential fraud or other misrepresentation of accounting or other information. opseo holds and retains records as per local laws/regulations and employees co-operate fully, openly, and honestly with internal/external auditors, tax authorities, and other regulators. opseo’s management team and the Finance & Controlling section ensure opseo complies with all applicable laws, external reporting standards and regulations, such as international and national accounting standards, financial regulator rules, HSE requirements, corporate governance codes, and regulatory standards.

Disclosure of information

opseo has Information Classification, Handling and Protection standards covering the use of information within opseo. All opseo employees must understand and adhere to these standards and take personal responsibility for the proper use, circulation, storage, protection, and disposal of opseo information. opseo information is only distributed on a “need-to-know” basis. All opseo employees must take care not to disclose information in public places and externally to third parties unless in accordance with the opseo Information Classification & Information Handling standards. This includes taking all the necessary steps to protect information in documents and on IT devices outside the workplace. opseo employees must also immediately report events which could impact the security of opseo information by following the information security reporting procedures. This includes, but is not limited to, clicking links or attachments in suspicious emails, inadvertently sharing confidential information with the wrong recipient, or any other relevant events.

Fair competition and antitrust

opseo co-operates fully with the competition authorities while consistently and robustly defending its legitimate interests.

opseo acts in the market as a fair and responsible competitor and undertakes to comply with applicable competition and antitrust laws. opseo does not participate in collusion or agreements with other companies that violate competition or antitrust laws. Our company’s competition policy shall be strictly followed by each of our employees.

Counterfeit parts and intellectual property

opseo employees are responsible for ensuring opseo’s assets are protected, including physical and intellectual property. All opseo employees must therefore report to opseo management if they suspect that any counterfeit product, service, communication, or marketing practice infringes opseo copyright, trademarks, patents, design rights, domain names, and/or any other intellectual property rights.

All opseo employees must ensure appropriate contracts are in place with clauses to protect opseo’s intellectual property rights and ensure freedom to use results when undertaking collaborative work with third parties. Moreover, opseo employees must make sure to perform the lawful checks and filings with respect to patents, designs and trademarks or other intellectual property rights when researching, developing or preparing to launch new products, brands, services, designs, inventions, communication, advertising, and promotional materials. opseo employees must not violate any valid patents, design rights, trademarks, copyrights, and other intellectual property rights of any third party. opseo employees do not remove any of opseo’s physical assets or property from company premises without permission or use them for inappropriate purposes.

Whistleblowing and protection against reprisals

opseo provides transparent, fair, and confidential procedures for employees to raise relevant concerns. These enable employees to discuss any situation where they believe they have been discriminated against or treated unfairly or without respect or dignity.

Environment

opseo’s Environmental Policy is a living document. This policy informs opseo’s ambition to minimize any negative environmental impact created by opseo and to use assets to boost opseo’s beneficial environmental impact. opseo communicates its environmental policy to employees and other stakeholders.

opseo is committed to complying with all applicable laws and regulations, will promote international harmonization of applicable laws and regulations, and is prepared to enter into voluntary agreements.

opseo expects its business partners to be committed to sustainable development.

opseo takes an enabling role towards sustainable development by investing in sustainable projects, increasing awareness, and kindling employees’ enthusiasm for the topic. Our yearly report reflects the efforts opseo has taken towards this goal.

opseo has its environmental performance measured and audited by a third party and publishes results annually, including validated and lawful environmental achievements. The environmental performance measured consists of calculating its energy efficiency, use of renewable energy, greenhouse gas emissions, water consumption, natural resources management, waste, and effect on air quality by measuring the carbon footprint. This calculation is done using the standard ISO 14069 principles, the Greenhouse Gas Protocol and the Bilan Carbone® method. Based on this annual calculation, opseo then identifies its biggest environmental impacts and seeks to lower them.

Even though not part of its core business, opseo is committed to responsible chemicals management by using recognized chemical management guidelines.

Interaction with local partners and business partners

opseo strives to maintain an open and cooperative relationship with our responsible local partners and business partners.

opseo pays particular attention to an open dialog at the municipal and local level in the regions where its business units are located.

Benefits and gifts

The acceptance of rewards, gifts or other benefits offered to employees in connection with their work by persons who have a business relationship with opseo or are seeking such a relationship is not permitted on principle.

Should acceptance be considered in exceptional cases, this must comply with internal guidelines. Consent is deemed granted if it concerns low-value gifts up to a customary market value of, in individual cases, an estimated EUR 20 and a total of no more than an estimated EUR 60 per year.

The acceptance of cash, regardless of the amount, is prohibited.

Otherwise, the internal rules shall apply.

Hospitality is only permissible in the context of events or work lunches, provided it is on an appropriate and socially adequate scale.

Implementation

Each and every opseo employee is responsible for complying with the rules of these ESG policies.

Superiors shall ensure that all employees are familiar with the contents of this policy and that statutory regulations are observed.

Through their conduct, managers act as role models.

Questions in connection with this Code of Conduct may be raised at any time with the managers or the Legal Division.

If an employee becomes aware of a serious violation of this Code of Conduct, the responsible line superior or the Legal Division must be informed immediately.

Information will be treated strictly confidentially.

Such information does not constitute denunciation but is intended to enable opseo to respond to possible violations in good time, to eliminate them or prevent them in the future.