This policy statement applies to the recruitment and placement of nursing staff from abroad for MEDIAN Unternehmensgruppe B.V. & Co. KG (MEDIAN) as well as for all affiliated companies in accordance with §§ 15 ff AktG.
This declaration is published on the MEDIAN website and can therefore be viewed by any interested person. Upon request, this declaration will be provided to contractual partners and employees in writing.
MEDIAN and all affiliated companies, their officers and directors are committed to complying with the WHO Global Code of Practice on the International Recruitment of Health Personnel and the WHO health workforce support and safeguards list (currently 2023; the next publication is expected to be 2026), as amended from time to time.
The WHO Global Code of Practice on the International Recruitment of Health Personnel contains, among other things, regulations on fair, transparent and non-discriminatory recruitment (Art. 3), on protecting the health systems of the countries of origin from excessive recruitment of healthcare professionals (Art. 3, 5) and on fair selection, treatment and remuneration (Art. 4).
The WHO health workforce support and safeguards list specifies in more detail that the recruitment of nurses in countries with a volatile, strained healthcare system should be avoided and contains a list of countries in which recruitment should be avoided for the benefit of the countries of origin.
Furthermore, MEDIAN and all affiliated companies are committed to the following international treaties in their respective applicable versions and the human rights stipulated therein:
The eight core conventions of the International Labor Organization:
Forced Labor Convention, 1930 (No. 29), Freedom of Association and Protection of the Right to Organize Convention, 1948 (No. 87), Right to Organize and Collective Bargaining Convention, 1949 (No. 98), Equal Remuneration Convention, 1951 (No. 100), Convention concerning the Abolition of Forced Labor, 1957 (No. 105), Convention concerning Discrimination in Respect of Employment and Occupation, 1958 (No. 111), Convention concerning the Minimum Age for Employment, 1973 (No. 138), Convention concerning the Worst Forms of Child Labor, 1999 (No. 182)
General principles and operational guidelines for fair recruitment and Definition of recruitment fees and related costs der International Labour Organization
Among other things, this publication differentiates between the costs incurred when recruiting foreign nursing staff and the extent to which the employer is entitled to demand reimbursement of these costs from its skilled workers.
United Nations Guiding Principles on Business and Human Rights der Vereinten Nationen
The UN Guiding Principles on Business and Human Rights state that companies have a responsibility to respect human rights and to prevent and remedy adverse impacts of their business activities on people.
MEDIAN regards a diverse, multinational workforce as a great strength and also wants to open up long-term personal and professional prospects and development opportunities for people with a migration background, enabling them to gain a long-term foothold in Germany. Against this background, MEDIAN and its affiliated companies are committed to the principles of fair recruitment and placement of nursing staff abroad as follows:
MEDIAN will not recruit professionals who come from countries listed in the WHO health workforce support and safeguards list.
All recruitment of foreign nursing staff must be carried out in writing or electronically. It must be possible to trace the recruitment process at any time.
MEDIAN and its affiliated companies do not require, directly or indirectly via third parties, the advance payment or reimbursement of costs, expenses or fees associated with the recruitment process from the recruited specialists.
The employer pays principle applies: MEDIAN and affiliated companies bear the entire costs of the recruitment process. This applies to the associated expenses such as language school, flight, the costs of the work permit, the residence permit and the recognition procedure.
No clauses will be included in employment contracts or other contracts of MEDIAN and affiliated companies that oblige foreign nursing staff to repay costs, expenses or fees arising from the placement.
If foreign nursing staff are recruited via third parties in the context of a commercial activity, MEDIAN and its affiliated companies prohibit any indirect obligation of the foreign nursing staff towards the third party that is to the benefit of MEDIAN or its affiliated companies by claiming costs, expenses or fees via the third party. If MEDIAN learns that third parties are demanding corresponding remuneration from foreign nursing staff for their work, MEDIAN will first seek a discussion, issue a warning to the contractual partner and, as a last resort, terminate the cooperation definitively.
MEDIAN and affiliated companies will not place foreign nursing staff in employment contracts if they would be directly or indirectly obliged to enter into commitment or repayment obligations.
MEDIAN has established a central responsibility for compliance with human rights and environmental obligations in the form of the Human Rights Officer. If you, as a foreign nursing professional, as an intermediary of foreign nursing professionals or in the context of your employment for MEDIAN or affiliated companies, find that MEDIAN or affiliated companies are violating this voluntary commitment, you have various options for lodging a complaint:
MEDIAN has set up a complaints procedure using the whistleblower system for reports in accordance with the Whistleblower Protection Act. This system allows complainants to submit information or complaints both by stating their name and anonymously. The whistleblower system is managed by the trusted lawyers of the law firm BETTE WESTENBERGER BRINK. The client relationship with MEDIAN guarantees the anonymity of complainants if this is desired. Even in the case of an anonymous report, complainants can remain in contact with the confidential lawyers via the whistleblower system after submitting the report. This system does not collect any personal data on the IT side (server logs, identifying cookies, etc.) nor does it force you to disclose your identity.
https://median-kliniken.advowhistle.de/Alternatively, you can contact the MEDIAN Group's Human Rights Officer: In-house lawyer Timo Behrend, Franklinstraße 28 - 29, 10587 Berlin, menschenrechte@median-kliniken.de, phone: 030 53005500.
In addition, the following rules of procedure apply to the processing of complaints:
Code of Procedure | MEDIAN Kliniken
If you have any questions about this policy statement, human rights or environmental issues, please contact the Human Rights Officer at any time.
Berlin, 14.04.2025