Compliance

Corporate Philosophy of CARE RECRUIT GmbH (CARE)

Preamble

CARE operates as a recruitment agency in the healthcare sector. Specifically, CARE places qualified personnel from third countries with German healthcare institutions. Based on ethical conviction and an awareness of our responsibility, we act in a helpful, friendly, considerate and fair manner towards all parties involved in the process. The company is committed to fair and ethically acceptable recruitment and placement practices.

Commitment to fair and ethically acceptable recruitment and placement practices

Fundamental to such practices are the principles of transparency – especially concerning structures, services, and costs – fairness, and the guarantee of sustainability, not only in relation to the healthcare systems of other countries but above all with regard to potential migrating nursing staff. No distinction is made between full-time and part-time nursing professionals.

CARE’s corporate policy is fundamentally based on the WHO Code of Practice on the International Recruitment of Health Personnel. CARE pays particular attention to the provisions of the WHO Global Code of Practice on the International Recruitment of Health Personnel and ensures that no recruitment is conducted from countries listed on the WHO health workforce support and safeguards list.

CARE is committed to the “employer pays” principle. This means that no employment relationships are brokered in which applicants have to pay for the placement. Any payments made by nursing staff to CARE, employers or third parties are not tolerated or initiated.

No agreements may be made that lead to a disproportionate burden in the event of contract termination or restrict freedom of movement for employees. In particular, loyalty or repayment clauses that contradict current legal standards or the principles of the “Fair Recruitment Care Germany” quality seal are not permitted. This also applies to side agreements or arrangements in connection with employment contracts, language courses, recognition procedures, relocation processes, or special cases such as the cancellation of the recruitment process.

CARE and all cooperation and business partners do not request or accept any form of payment from nursing professionals, whether preventive (e.g. deposits) or retrospective (e.g. contractual penalties). This prohibition on payments is passed along the entire service chain.

International standards and principles

CARE acts in accordance with the following international principles and agreements:

ILO Core Labour Standards, in particular the “ILO General principles and operational guidelines for fair recruitment and definition of recruitment fees and related costs”
UN Guiding Principles on Business and Human Rights
International Human Rights Treaties of the United Nations

Minimum requirements regarding human, migration and labour rights

CARE is familiar with all conventions ratified by the Federal Republic of Germany for the protection of human rights, migration rights and labour rights and is committed to upholding them. These conventions, together with the German Basic Law, define the legal minimum standards for CARE’s actions.

Within the limits of what is legally possible, CARE ensures that its business partners also comply with these minimum standards. The requirements are contractually incorporated.

Business partners include all parties involved in the process of placement, education, training or employment of foreign nursing staff. CARE explicitly distances itself from racism, exploitation, unequal treatment and other serious violations of these core values.

Compliance with these minimum standards is regularly reviewed both internally at CARE and, to the extent possible, with business partners.

As of: 02-2025

Code of Conduct of CARE RECRUIT GmbH (CARE)

The standards set out in this policy are not a matter of course in the field of recruitment and personnel placement from third countries. When it comes to the placement and integration of skilled workers, the satisfaction of all parties involved and a fair, honest and transparent approach are essential to sustainable success.

CARE ensures and expects this behaviour in dealing with business partners, contractors, their subcontractors and service providers as the basis of every business relationship. CARE observes the following requirements for a reputable recruitment agency operating in third countries:

Principles in the placement process

Recruitment and placement are free of charge for the candidate.
The employer is responsible for the complete financing of language courses. CARE ensures that candidates do not incur any direct or indirect costs. CARE takes over the financing of language courses up to level B1 on behalf of the employer. These costs are later offset against the placement fee.
CARE ensures a high quality of German language teaching in the home country by working with qualified language schools that meet recognized certifications.
CARE takes over the entire administrative process for the assignment until entry into Germany. This includes the compilation, translation and declaration of all relevant documents, as well as communication with embassies, consulates and immigration authorities.
Only certified translators or translators recognized by German missions abroad are commissioned. All documents are submitted in certified form to the relevant authorities.
CARE takes over the coordination and submission of the recognition documents to the relevant authorities and maintains contact with the relevant offices in the federal states, unless otherwise regulated by the employer.
In the country of origin, CARE works exclusively with carefully selected partners who do not charge candidates.
CARE remains a constant companion, confidant and point of contact for the candidates throughout the entire process: from recruitment to placement to recognition in Germany.
CARE adheres to the WHO Code and does not recruit professionals from countries on the WHO list of banned states for the health sector.

Requirements for our partners abroad

Our partners offer language courses with trained teachers who have a degree in German as a foreign language (DaF) or a comparable qualification.
Class sizes are limited to a maximum of 25 participants. Small groups ensure a higher quality of teaching and individual support.
The aim is to have a sufficient number of German-speaking native speakers with a pedagogical education. Where this is not possible abroad, other qualified teachers are used.
Teaching is carried out using regular and recognized teaching materials.

Our quality controls

CARE continuously monitors compliance with quality standards throughout the entire placement process – both internally and with partners in Germany and abroad. Our Code of Conduct is binding for all parties involved.

As of: 02-2025

Complaints Management of CARE RECRUIT GmbH (CARE)

1. General

1.1. Definition

A grievance mechanism is a process that provides a way to submit complaints related to the social and labor impacts of business operations. It is a way to report social and labor impacts and risks that could become impacts. Grievances can be communicated by those affected themselves or by representatives such as organizations.

The company has a detailed and written process for handling complaints. This includes a clear procedure, the designation of contact persons to process the complaints, and the definition of an appropriate time frame for the complaint’s procedure.

A complaint is any negative statement or dissatisfaction expressed by the customer/applicant or a third party on behalf of a customer/applicant (e.g. authorized attorneys), from ombudsmen or regulatory authorities – regardless of their form – that is addressed to CARE.

A complaint is any expression of dissatisfaction that a natural person (complainant) addresses to a company in connection with the provision of a service or a corresponding process. This does not include services under the quality seal for which CARE is not responsible.

The term “complaint” does not have to be used. A complaint does not need to be in any particular form. If there is any doubt as to whether the statement is to be understood as a complaint, it must be submitted to the complaints management officer, who decides whether the statement qualifies as a complaint. His decision is binding for the processing.

1.2. Scope

In accordance with the quality seal, CARE is obliged to have a proper business organization that ensures compliance with the legal provisions to be observed by them.

This includes CARE reliably recording and evaluating complaints in order to gain insights into possible omissions and inadequacies in business operations and to be able to remedy them. The insights gained from complaints processing are incorporated into the business processes and taken into account in their further development.

The scope of application of this complaints management guideline applies to all complaints. Observing and complying with the provisions of this complaints management guideline is mandatory for all CARE employees and members of the management. The guideline and the complaints protocol are accessible to all employees at all times. Employees will be informed of any changes to the guidelines.

2. Complaint Management

2.1. Objectives

The objectives of complaint management are as follows:

Correcting mistakes
Restoring applicant and customer satisfaction
Improving customer retention
Changing decisions and processes
Apologizing for inappropriate employee behavior
Compensation and reimbursement of expenses
Information on weaknesses in the service or deficiencies in service quality
Response to customer and applicant requests
Safeguarding the interests of stakeholders and shareholders
Reducing error and complaint costs
Recording and evaluating complaints for quality assurance purposes and improvement, if necessary, modification of processes
Use of complaint information with regard to operational risks and opportunities in the market
Increasing service quality
Systematic handling in customer dialog

2.2. Principles

The complaints management is guided by the following principles:

Appointment of a representative to whom all complaints are to be forwarded
Creation of a process flow
Continuous improvement of the process
Customer orientation
Fact-based decision-making in the best possible customer interest
Involvement of the persons involved
Regular reporting to the management

2.3. Process

Complaint management is to be subdivided into a direct and an indirect process.

The tasks of the direct process are to be subdivided into:

Complaint stimulation
Complaint acceptance
Complaint processing
Complaint reaction

The indirect process can be subdivided into the following areas of responsibility:

Complaint analysis
Complaint reporting
Use of information

2.4. Complaints register

All complaints, the way they are processed, the measures taken and the decisions are systematically documented (complaints register) without undue delay. The complaints register is maintained electronically and in a physical folder so that it enables systematic evaluation, is protected against changes that are not factually necessary, reveals subsequent changes and ensures unimpeded inspection by the responsible employees of the central complaints office.

The documents available for a complaint are kept for five years. The data from the complaint processing are continuously analyzed to ensure that recurring or systematic problems and potential legal and operational risks are identified and remedied, e.g. by means of the following measures:

Analysis of the background to each individual complaint to identify causes common to certain types of complaints
Consideration of whether these causes could also influence other processes or services – this also applies to processes and services about which no complaints have been made
Removal of causes, as far as reasonable and possible

3. Process owners

To ensure efficient complaint management, the management has set up an external complaints office at a law firm. The external complaints office can be reached via the email address feedback.care-recruit@zkkh.de.

Within the complaint’s procedure, the responsible office checks the respective complaint upon receipt. In the event of significant risks, the complaints officer informs the management.

4. Complaints procedure

The complaints procedure is clearly regulated, freely accessible and transparent. The options for lodging a complaint must be simple and publicly accessible.

There is online access to a complaints procedure for interested parties, such as for the foreign nursing staff to be placed, external service providers, employees and employers/clients.

4.1. Complaints to be processed

Complaints to be processed in accordance with these guidelines are negative statements or expressions of dissatisfaction relating to the following issues:

Breach of contractual obligations
Dissatisfaction with advertising measures
Defective processes
Threat of legal action
Assertion of claims
Complaints with threats of termination or associated with a termination or a request for contract termination/reverse transaction
Risk of reputational damage (e.g. due to publication of the facts)

Enquiries and requests for information or similar are not complaints.

4.2. Complaint stimulation

The complaints management system must provide suitable, perceptible points of contact. It must be clearly communicated to whom complaints are to be addressed. CARE uses easily accessible channels for this purpose, which are also announced on the website.

4.3. Complaint registration

The complaint is processed by the external complaints office. Written complaints are acknowledged if no immediate response is provided. Every complaint – whether by phone or in writing – is documented in the complaints log.

4.4. Complaint handling and response

The external complaints office is responsible for handling the complaint until the final response. This should be done within five working days, in writing or orally if requested. In complex cases, the deadline can be extended for objective reasons.

The complaint is forwarded to the responsible departments at CARE. The aim is to find a quick solution in the interest of the complainant. It is mandatory to document deadlines. Communication is always handled by the person responsible for the complaint.

Repeat complaints are assigned to the original processing point. In the event of potential legal action, the retention of documents is ensured.

4.5. Complaint analysis

Complaints are systematically recorded, analysed and used for optimization. Possible causes are identified. The complaints are assigned to at least the following categories:

Complaints of contract violations
Dissatisfaction with the performance of the service
Threat of legal action
Terminations

The external complaints office makes suggestions for improvement to the management, which is responsible for implementing them.

4.6. Complaints reporting

The external office reports to the management every six months and every year. The report includes the following information:

Extent of complaints (number and processing time)
Distribution across company divisions
Systematic cause analysis
Development of improvement measures

Information about serious complaints or risks to reputation is provided immediately, especially for major customers or high risks of damage.

4.7. Use of information

The findings from the complaint analysis are incorporated into the company organization. Processes are improved, costs reduced, and the quality of complaint management increased.

5. Measures in the event of violations of the complaint management guideline

In the event of a violation of this complaints management policy, the cause or weakness in the work or process flow that led to this violation is to be determined by the external complaints office and eliminated by the management without delay.

CARE’s management must always be informed of violations of this policy, even if complaints concern external service providers.

6. Further development of the complaints management policy

CARE’s management and the external complaints office are responsible for the ongoing development and maintenance of the policy. The management decides on necessary changes or additions and publishes them on the CARE website. Employees are informed of updates.

The policy, in particular its principles and procedures, should be reviewed annually.

7. Monitoring

The implementation of and compliance with the complaints management policy will be regularly monitored by CARE’s management.

8. Possible interested parties (stakeholders)

The following parties may be the recipients of a complaint or feedback:

Customers/Clients
Agencies
Service providers (e.g. translators, notaries, courier services, language schools)
International nurse to be placed
Internal employees
Company owners
National authorities (e.g. German Embassy)
International authorities

9. Possible scenarios for / from practice

I. Complaints from customers

1. About / regarding CARE employees

The recipient of the complaint informs the person concerned (= person responsible for the complaint) about the complaint
An exchange about the facts is sought internally and externally
Information about the facts is collected
The cause of the complaint is discussed
If necessary, the facts and the relevant measures are reported to management
An explanation and, if necessary, a suggestion for improvement is submitted to the complaints management officer
The consent or at least the acknowledgement of the complaints management officer is obtained
If necessary, changes in the way the organization works or communicates with the customer
The process is documented and stored for the purpose of standardizing and preventing similar cases
Potentially all employees can be responsible
Processing time: max. five working days

2. Regarding the recruitment and placement process

The recipient of the complaint informs the person responsible for complaints
Internal and external exchange of information about the facts
Collection of relevant information
Clarification of the cause of the complaint
If necessary, information of the management and initiation of measures
Suggestions for improvement are submitted to the complaints management officer
The consent/acknowledgment of the officer is obtained
Contractual changes if necessary
Documentation and storage for quality assurance
Processing without undue delay, max. five working days

Contact person: Dr. Hanno Kiesel
Email: feedback.care-recruit@zkkh.de

3. Regarding future employees (= international nurse to be placed)

The recipient of the complaint informs the person in charge
Internal/external exchange on the facts of the case is sought
Collection and analysis of the facts
Clarification of the cause, if necessary, in consultation with the specialist or partners abroad
Management is informed if necessary
Suggestions for improvement are made
Clarity and agreement by the complaints management officer
Documentation and preventive storage
Timely processing in max. five working days

Contact person: Dr. Hanno Kiesel
Email: feedback.care-recruit@zkkh.de

4. Further contractual agreements

Information of the responsible person by the recipient of the complaint
Internal/external exchange of information on the facts of the case
Data collection on the case
Analysis of the causes
Report and forwarding of measures to management
Suggestions to the complaints management representative
Acknowledgment and/or agreement by the representative
Contract adjustment if necessary
Documentation & securing of the case for reuse
Processing time max. five working days

Contact person: Dr. Hanno Kiesel
Email: feedback.care-recruit@zkkh.de

II. Complaints from nursing staff to be placed

1. Regarding CARE employees

The person receiving the complaint informs the person concerned (= person responsible for the complaint) about the complaint
An internal and external exchange about the facts of the case is sought
Information about the facts of the case is collected
The cause of the complaint is discussed
If necessary, management is informed
Suggestions for improvement to the complaints management officer
The knowledge or consent of the officer is obtained
If necessary, adjustment of communication with the caregiver
Documenting and securing the process
Responsible: potentially all employees
Processing period: five working days

2. Regarding the recruitment and placement process

The recipient of the complaint informs the responsible person
Internal and external exchange about the facts
Gathering information
Clarifying the cause
Informing management if necessary
Suggestions for improvement are forwarded
Approval or acknowledgement of the representative
Communication is adapted if necessary
Documentation for quality assurance
Processing without undue delay, deadline: five working days

3. Regarding future employers

Information for the responsible person
Internal and external exchange of information
Collection of information and clarification of causes
Inform management if necessary
Forward suggestions for improvement
Acknowledgment or agreement of the representative
Adjustment of communication with the nurse
Documentation to avoid recurring complaints
Processing time: five working days

4. Regarding existing employers

The recipient of the complaint informs the person in charge
Internal/external exchange
Information and cause analysis
Inform management if necessary
Forward suggestions for improvement
Acknowledgment or agreement of the representative
Adjustment of communication with the nurse
Documentation of the entire process
Deadline: one working week

5. Language schools operated by language schools or foreign agencies

The recipient of the complaint informs the person responsible (= person responsible for the complaint) about the complaint
An exchange of information about the facts is sought internally and externally
Information about the facts is collected
The cause of the complaint is discussed
If necessary, the facts and the relevant measures are reported to management
An explanation and, if necessary, a suggestion for improvement is provided to the complainant (= complaints management officer)
The consent or at least the acknowledgement of the complainant is obtained
If necessary, changes are made in the way the company works or communicates with the potential nurse and with the language schools
The entire process is documented and stored
Potentially all employees can be responsible
Processing time: max. five working days

6. Regarding violations of the WHO Code of Conduct

The recipient of the complaint informs the person responsible (= complaint officer) about the complaint
An exchange of views on the facts of the case is sought internally and externally
Information about the facts of the case is collected
The cause of the complaint is discussed
The facts of the case are examined on the basis of the WHO Code of Conduct (top priority: compliance)
If necessary, the facts and the relevant measures are reported to management
An explanation and, if necessary, a suggestion for improvement is provided to the complainant (= complaints management officer)
The consent or at least the acknowledgement of the complainant is obtained
If necessary, changes are made in the way the potential caregiver works or how they communicate with them
The entire process is documented and stored
Potentially all employees can be responsible
Processing time: max. five working days

III. Complaints from CARE employees

1. About other CARE employees

The person concerned (= person responsible for the complaint) informs the recipient of the complaint about the complaint
An exchange about the facts of the case is sought internally in an open discussion
The cause of the complaint is discussed
If necessary, the facts and the relevant measures are reported to management (only as a last resort)
An explanation and, if necessary, a suggestion for improvement is provided to the complainant (= complaints management officer)
The consent of the complainant to the handling of the complaint is obtained
If necessary, changes are made to the way the team works or communicates
The entire process is documented and stored
Potentially all employees can be responsible
Processing without culpable delay, max. 5 working days

2. Regarding working hours or employment relationships

The recipient of the complaint informs the responsible person (= person responsible for the complaint) about the complaint
An internal exchange about the facts of the case is sought
Information is collected and causes are discussed
If necessary, a report is sent to management
Suggestions for improvement are conveyed to the complainant
The consent of the complainant is obtained
If necessary, changes are made to the team or communication
Documentation for future use
Potentially all employees can be responsible
Processing without culpable delay, max. 5 working days

3. Regarding third parties

The recipient of the complaint informs the responsible person (= person responsible for the complaint) about the complaint
An internal and external exchange of information on the facts of the case is sought
Information about the facts of the case is collected
The cause is discussed and, if necessary, reported to management
Suggestions for improvement are communicated to the complainant
The consent or acknowledgement of the complainant is obtained
If necessary, adjustments are made to the way the team works or communicates
Complete documentation and securing of the records
Potentially all employees can be responsible
Processing without undue delay, max. 5 working days

IV. Complaints from others

1. From national authorities

The recipient of the complaint informs the person in charge (= person responsible for complaints) about the complaint
An exchange about the facts of the case is sought internally and externally
Information about the facts of the case is collected
The cause of the complaint is discussed
If necessary, the facts of the case and the relevant measures are reported to management
An explanation and, if necessary, a suggestion for improvement is provided to the complainant (= complaints management officer)
The consent of the complainant is obtained
If necessary, changes in working methods or communication within the team
Documentation and storage to prevent similar incidents
Measures must also have an external impact
Potentially all employees can be responsible
Processing takes place without undue delay, max. 5 working days

2. From international authorities

The recipient of the complaint informs the person in charge (= person responsible for the complaint) about the complaint
An exchange about the facts of the case is sought internally and externally
Information about the facts of the case is collected
The cause of the complaint is discussed
If necessary, the facts of the case and the relevant measures are reported to management
An explanation and, if necessary, a suggestion for improvement is provided to the complainant (= complaints management officer)
The consent of the complainant is obtained
If necessary, changes in working methods or communication within the team
Documentation and storage to prevent similar incidents
Measures must also have an external impact
Potentially all employees can be responsible
Processing takes place without culpable delay, max. 5 working days

Rev.: 2025-01 / As of: 03-2025