Compliance Management System - Gerresheimer



A Compliance Management System (CMS) was introduced in the Gerresheimer Group back in 2009 and has been continuously developed and adapted to current requirements and amendments to the law ever since.

Our CMS focuses on the following areas:

  • Respect for human rights,
  • Avoidance of antitrust and competition law risks,
  • Combating corruption and money laundering,
  • Compliance with data protection laws & guidelines and
  • Export control.


The key elements of the CMS include the Gerresheimer Compliance Program, classroom training, web-based e-learning programs and a whistleblower system, which can also be used to submit reports in anonymized form if desired.

Compliance Organization

Compliance is managed by the Corporate Legal & Compliance department based at the headquarters in Düsseldorf. In order to meet the requirements of legislation and market requirements, the position of Head of Compliance was created and staffed in 2022. Each company in the Gerresheimer Group has appointed a person who is responsible for compliance in that company. There is also a Compliance Officer at locations with their own legal department. The Head of Compliance regularly reports to the Audit Committee of the Supervisory Board of Gerresheimer AG on the current status of compliance. The Head of Compliance also works closely with the Internal Audit department, which also regularly audits individual components of the CMS.

Gerresheimer Compliance Program

The Gerresheimer CMS is intended to support our employees in applying laws and company guidelines correctly and thus protect them from violations. All guidelines, documents, templates, etc. are therefore easily accessible to all employees on the intranet site. The available guidelines include Compliance Organization, Internal Investigations & Whistleblower Protection, Conduct during Searches, Antitrust Law, Capital Market Law, etc. Most of the guidelines are available in 10 languages to provide employees worldwide with easy access to the information.

Employee training

In accordance with our Compliance Organization Policy, we conduct training courses both in person and online as e-learning. In the classroom training sessions, employees are given an overview of the CMS at Gerresheimer and are provided with information on where to find further material.

The e-learning modules cover the topics of compliance in general, data protection, protection against corruption, fraud prevention, fair competition and responsibility in exports. All modules are available in 10 languages.

Receipt of information and whistleblower protection

Another important component of the CMS is our procedure for receiving and processing reports and protecting whistleblowers.

We have set out the details of the options for submitting information to us (reporting channels), how we process such information and how we protect whistleblowers in Rules of Procedure. These can be downloaded in numerous languages.

Our procedures for receiving reports include the electronic whistleblower system. It enables a direct dialog with the Head of Compliance via the Internet worldwide and around the clock. The whistleblowers decide for themselves whether they wish to remain anonymous. To make access as easy as possible, the whistleblower system can be used in all languages relevant to the

Export control

We use a license from a specialist service provider to ensure that we are always up to date with regard to possible sanctions. In this way, the relevant databases of our ERP system are continuously checked with regard to current direct sanction measures of the EU, the USA and various international sanction regimes. This system is used worldwide within the Gerresheimer Group.



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