Code of Conduct for Suppliers of MedVision AG (Supplier Codex)
RECITALS
MedVision AG provides medical facilities with software, hardware and service solutions that enable them to provide targeted, effective and efficient patient care. In addition to ensuring a high level of security for the data processed by MedVision, our customers and suppliers, MedVision attaches the utmost importance to the safety of the patients treated by our customers and to compliance with all laws, standards and regulations.
MedVision AG strives to conduct all business relationships on the basis of integrity, respect and sustainability. This Supplier Codex defines the minimum requirements that all suppliers must comply with in terms of ethical behaviour, social responsibility and environmental protection in order to maintain a business relationship with MedVision AG;
it serves as a guide for our suppliers to ensure that they share and adhere to our values and expectations.
This Code of Conduct for Suppliers of MedVision AG (Supplier Codex) applies to external third-party providers, their affiliated companies and subcontractors, who as contractors, service providers, consultants, suppliers and other intermediaries (hereinafter referred to as "Suppliers") provide goods and/or services to MedVision AG and its subsidiaries (hereinafter referred to as "MedVision", "we" or "us").
This Supplier Codex sets out MedVision's expectations of Suppliers in terms of minimum requirements. In order to meet the requirements described in this Supplier Codex, MedVision Suppliers shall implement appropriate procedures within their companies as well as in their value and supply chains.
PRINCIPLES FOR SUPPLIERS: LAWFUL AND INTEGRITY-BASED CONDUCT
MedVision expects Suppliers to conduct their business in a lawful, ethically responsible and honest manner.
1. Lawful Behaviour
For MedVision, compliance with laws, applicable standards and regulations is a fundamental principle of all business activities.
MedVision therefore expects Suppliers to comply with all legal provisions, national, European and international laws, regulations and directives relevant to their business, in particular regarding:
- labour law and social standards
- environmental protection
- product safety and quality
- data protection (in particular GDPR, BDSG)
- anti-corruption and
- antitrust regulations
as well as all fundamental ethical principles at all times and in all places, and to introduce appropriate procedures for this purpose; no prohibited actions may be taken, even if this leads to economic disadvantages.
Suppliers undertake to support MedVision in fulfilling extended legal and declaratory requirements, in particular to prepare and maintain the necessary documentation in a proper and complete manner and to submit it to MedVision upon request. Suppliers shall inform MedVision immediately of any dangers and risks that may affect MedVision or MedVision's customers.
MedVision conducts itself in a lawful, professional, honest and fair manner in all dealings with business partners and expects the same from all its Suppliers.
2. Human Rights and Working Conditions
MedVision Suppliers respect and support the protection of international human rights within their sphere of influence and do not contribute to human rights violations.
MedVision Suppliers are obliged to comply with all labour and social legislation and to ensure fair working conditions, including freedom of association, reasonable working hours and fair and gender-neutral pay.
MedVision strictly rejects any form of forced or compulsory labour, slavery, child labour, undeclared work and illegal employment: MedVision's Suppliers are obliged to comply with all relevant legal provisions (including international conventions and agreements, legislation on working time, occupational health and safety, regulations on the hiring and posting of workers, social security and residence rights).
MedVision Suppliers are prohibited from any discrimination based on national and ethnic origin, social background, health status, gender, sexual orientation, religion, ideology or political opinion, age or disability, unless different treatment is justified by the requirements of the job.
3. Environmental protection and sustainability
MedVision Suppliers must comply with all legal requirements for the protection of the environment, the climate and the sustainable and careful use of natural resources, avoid harmful emissions to soil, water, air and noise, and comply with all applicable regulations and standards concerning the proper and environmentally friendly handling, storage and disposal of waste, the safe handling of hazardous substances and contaminated sites, and obtain and maintain all necessary official approvals.
MedVision's Suppliers are committed to sustainability and strive to use resources efficiently and reduce unavoidable environmental impacts to the lowest possible level, both technically and organisationally.
BUSINESS RELATIONSHIPS & COMPLIANCE
MedVision stands out from the competition thanks to its superior products and services. We do not tolerate corruption, antitrust violations, money laundering or violations of trade bans and restrictions (zero tolerance):
MedVision does not engage in any business that cannot be achieved without such practices.
In business relationships, conflicts of interest must be disclosed, all forms of corruption must be avoided, the requirements of free competition must be upheld, trade bans and restrictions must be observed, money laundering must be combated, and all product safety and quality requirements must be met.
In detail:
1. Avoiding Conflicts of Interest
MedVision expects every Supplier to avoid conflicts of interest that could interfere with an objective and fair business relationship with MedVision or that could compromise the business relationship with MedVision;
every Supplier shall immediately inform MedVision of and fully disclose any potential conflicts of interest.
2. Anti-Corruption and Gifts
Suppliers of MedVision may not offer or grant MedVision employees any inappropriate personal benefit (money, gifts, services or other benefits such as personal advantages or favours), nor may they demand or accept such benefits from our employees.
Suppliers of MedVision may not offer, promise, grant, demand or accept inappropriate personal benefits to or from natural or legal persons in order to secure new business deals, maintain existing contracts or obtain other inappropriate advantages.
Gifts and invitations are only permissible if they are appropriate and do not give the impression that they are intended to influence the recipient to act improperly, provided they are granted transparently and properly documented. Relevant country-specific laws must be observed.
3. Antitrust and Competition
MedVision is committed to the principles of free and fair competition. MedVision Suppliers undertake to comply with the provisions of antitrust, competition and public procurement law protecting free and fair competition. MedVision Suppliers shall not enter into any formal or informal agreements with other (and in particular not with competing) companies that could distort or restrict competition (this includes, in particular, horizontal or vertical price fixing agreements, customer or territory allocations or quota agreements, but also the mere exchange of commercially sensitive information and trade secrets).
4. International Trade Control
MedVision Suppliers shall comply with all applicable national and international trade control laws and provide the relevant (customs) authorities with all necessary information in a complete and truthful manner.
5. Anti-Money Laundering
MedVision Suppliers comply with all legal obligations regarding the prevention of money laundering and take all necessary measures to prevent activities that could constitute illegal money laundering. This includes the clear identification of all business partners, the avoidance of anonymous financial transactions, and the complete traceability of all payments and their origin.
6. Product Safety and Product Quality
MedVision Suppliers undertake to always comply with the contractually agreed or generally recognised quality standards and applicable product safety regulations for goods and services supplied to MedVision, and to label their products correctly: Suppliers shall immediately provide MedVision with all required product information, safety data sheets, notification or registration confirmations, use cases and hazard scenarios, as well as safetyrelated information.
7. Data protection and confidentiality
MedVision Suppliers shall treat all information relating to their business relationship with and the business activities of MedVision, as well as MedVision's trade and business secrets, intellectual property and confidential information (including all non-public strategic, financial, technical or business information) ("Confidential Information") as strictly confidential.
MedVision Suppliers shall protect Confidential Information by taking appropriate technical and organisational measures and exclusively use Confidential Information within the scope of their supply relationship with MedVision; Suppliers shall communicate Confidential Information to authorised recipients only and only to the extent necessary for them to perform their tasks in supplying MedVision.
MedVision Suppliers respect the sensitivity of personal data when collecting, storing and using it; Suppliers protect personal data by handling it carefully and responsibly and comply with the applicable data protection regulations for the protection of personal data, in particular the General Data Protection Regulation (GDPR) and other applicable data protection laws.
MONITORING & COMPLIANCE, CONSEQUENCES OF VIOLATIONS
In order to comply with the requirements of this Supplier Codex, MedVision Suppliers shall incorporate its key aspects into their own processes and guidelines and shall devote appropriate resources to ensuring compliance.
1. Implementation and Monitoring of the Principles of the Supplier Codex
MedVision Suppliers shall ensure compliance with the provisions of this Supplier Codex through appropriate internal management systems and control mechanisms: These shall enable the continuous identification and assessment of risks in the areas covered by this Supplier Codex, as well as measures to eliminate or reduce identified risks. Proper documentation may evidence compliance with the principles of this Supplier Codex.
MedVision reserves the right to verify compliance with the principles of this Supplier Codex in an appropriate manner, including, if necessary, by means of audits conducted by MedVision or by qualified third parties commissioned by MedVision. Audits shall be conducted during normal business hours, be announced in advance in writing and agreed upon, unless unannounced audits have been contractually agreed upon.
2. Reports; consequences of violations
MedVision Suppliers shall immediately report to MedVision any violations of the principles of this Supplier Codex that may affect the business relationship with MedVision or MedVision customers. MedVision will work with the Supplier to design and implement appropriate corrective measures.
Compliance with this Supplier Codex is an important aspect of supplier selection: Violations may result in us reconsidering and terminating our business relationship with non-compliant Suppliers.
3. Changes to the Supplier Codex
MedVision reserves the right to amend this Supplier Codex from time to time, in particular to adapt it to new legal requirements. MedVision Suppliers will be informed of any such amendments.
4. Acceptance of and Adherence to Supplier Codex
The establishment and continuation of a business relationship with MedVision AG depends largely on Suppliers taking note of, accepting and complying with this Supplier Codex.
By accepting an order or purchase order from MedVision, Suppliers of MedVision agree to this Supplier Codex in its current version and accept its validity for their entire business relationship with MedVision AG.
CONTACT FOR MEDVISION SUPPLIERS
If you have any questions or comments regarding the application and implementation of this Supplier Code, the following contact persons are available to MedVision suppliers:
Medvision AG Purchasing Department, Phone: +49 (0)2303 25202910, Email: einkauf@medvision.de
The Supplier Codex is current as of 5 March 2025.
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