Human Rights and Compliance Sustainability Program Lead

PURPOSE AND SCOPE:

Supports the company’s mission, vision, core values, and customer service philosophy. Adheres to the Corporate Compliance Program, including all applicable laws, regulations, policies, and procedures.

Serves as a member of the Human Rights Office within the Global Compliance team, supporting and advancing the organization’s compliance program with primary responsibility for human rights due diligence (HRDD) and sustainability-related compliance reporting.

Acts as a member of the Human Rights Office pursuant to §4(3) of the German Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz, LkSG) and serves as the senior subject-matter expert for the global HRDD program across company operations and the value chain. Leads the implementation, monitoring, and continuous improvement of the HRDD program in alignment with the LkSG, the EU Corporate Sustainability Due Diligence Directive (CSDDD), the Corporate Sustainability Reporting Directive (CSRD/ESRS), the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, and other applicable legal and regulatory requirements.

This individual contributor role has no direct reports and achieves results through subject-matter expertise, cross-functional collaboration, and project management. Regularly informs senior management of the company’s human rights performance in accordance with §4(3) LkSG.

PRINCIPAL DUTIES AND RESPONSIBILITIES:

• Applies a highly advanced specialist knowledge of business and human rights, sustainability reporting and a developed understanding of the business of the organization.

• Acts as an accessible, visible, and available subject-matter expert and the primary point of contact for human rights matters across the organization.

• Coordinates preparation of human rights and compliance-related data supporting sustainability reporting obligations, including CSRD/ESRS and other applicable regulatory reporting requirements.

• Responsible for monitoring the effectiveness of the human rights risk management system, and informs senior management regularly about this work.

• Maintains current knowledge of law, regulation, standards, and market changes that impact human rights due diligence obligations across all relevant jurisdictions.

• Monitors developments at the international (UN, OECD), EU (CSDDD, CSRD, Forced Labour Regulation, Conflict Minerals Regulation), and national levels, and assesses implications for the program.

• Establishes respect for human rights as a strategic priority and helps instill a supportive culture throughout the organization.

• Provides technical expertise, corrective action planning, and human rights consultation to business functions as needed.

• Leads preparation of draft responses and supporting materials for the Annual General Shareholders’ Meeting relating to human rights and compliance topics.

• Viewed as the department’s leading authority on human rights due diligence, demonstrating a high level of expertise and strong capability in the subject matter.

Human Rights Due Diligence Program

• Operates and further develops the global human rights due diligence program, including optimization of processes, procedures, policies, training, and IT tools.

• Maintains the human rights policy statement (Grundsatzerklärung) and the organization’s human rights commitments, updating them annually and upon material change.

• Monitors regulatory developments and adapts the program accordingly, including attending relevant events and associations and conducting research.

• Support development and delivery of human rights awareness and training, including function-specific training for higher-risk areas (e.g., Procurement, HR) and global awareness training for employees.

Risk Analysis and Operations

• Together with respective functions and stakeholders, conducts the regular (at least annual) and ad-hoc human rights risk analysis covering the organization’s own operations and its supply chain.

• Identifies key human rights risk areas and designs mitigating and preventive measures, tracking their status within the human rights risk management framework.

• Coordinates supplier-related due diligence in partnership with Procurement, including risk-based audits, contractual cascading, and conflict-minerals due diligence.

• Monitors, analyzes, assesses, and documents business transactions, processes, structures, and external developments relevant to identifying human rights risks.

• Supports the remediation of identified adverse human rights impacts and tracks corrective action to completion to strengthen the effectiveness of the human rights due diligence program.

Grievance Mechanism and Remediation

• Administers the human rights complaints procedure, ensuring it is accessible, confidential, and provides protection from retaliation for anyone potentially affected.

• Reviews the effectiveness of the complaints procedure at least annually and on substantial change, benchmarking against recognized effectiveness criteria.

• Maintains case documentation and aggregated reporting on grievances received, handled, and resolved.

Reporting and Collaboration

• Prepares human rights disclosures for regulatory filings and sustainability reporting, including CSRD/ESRS S1–S4 content, LkSG documentation, and applicable foreign-law statements (e.g. UK Modern Slavery Act, Canadian Forced Labour Act).

• Reports or supports the reporting regularly and ad hoc to the [the Human Rights Steering Committee or the Management Board] with respect to the area of responsibility.

• Collaborates cross-functionally with Procurement, Human Resources, Sustainability, Legal, Internal Audit, Regulatory Affairs, and Data Protection, influencing without direct authority.

• Provides input to support ESG ratings and requests of rating agencies.

• Maintains documentation demonstrating fulfillment of applicable due diligence and reporting obligations.

• Builds and maintains key internal and external contacts and partnerships to enable effective dialogue on human rights.

PHYSICAL DEMANDS AND WORKING CONDITIONS:

• The physical demands and work environment characteristics described here are representative of those an employee encounters while performing the essential functions of this job.

• Up to 25% travel required.

SUPERVISION:

• None. This is an individual-contributor specialist role with no direct reports.

EDUCATION:

• Bachelor’s degree required.

• Master’s degree or equivalent qualification in Law, Business, Economics, Human Rights, Political Science, or similar preferred.

• Professional certifications in compliance, ethics, human rights due diligence, or ESG are preferred.

EXPERIENCE AND QUALIFICATIONS:

• Minimum of 6 years of progressive experience in compliance, human rights, ESG, sustainability reporting, legal, or a related field, preferably within a multinational organization or the healthcare industry.

• Fluency in German and English (written and verbal) required.

• Deep knowledge of human rights due diligence frameworks, including LkSG, CSDDD, CSRD/ESRS, the UN Guiding Principles, and the OECD Guidelines.

• Strong knowledge of corporate compliance, ethics, governance, and sustainability reporting requirements.

• Demonstrated experience implementing compliance, sustainability, or human rights due diligence programs and managing complex cross-functional initiatives.

• Strong analytical, organizational, project management, and written communication skills, including preparing executive presentations and regulatory reports.

• Ability to influence stakeholders without direct authority while managing multiple priorities in a global environment.

• Demonstrated integrity, professionalism, discretion, and sound judgment.

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