Transcura recruits nursing staff from third countries in compliance with fair and ethical recruitment
and placement practices by ensuring that:

1. the guidelines are applied in accordance with the six guiding principles of the "Fair Recruitment Care Germany" quality seal, namely
   - Written form for verifiability
   - The placement process is free of charge for the nursing professionals
   - Limitation of the economic risk for nursing professionals
   - Transparency regarding structures, services and costs
   - Sustainability and participation
   - Overall responsibility
2. the placement of candidates is fair, transparent and aligned with the WHO Code of Conduct for the International Recruitment of Health Professionals.
3. ensuring at all times that international human rights conventions and human rights standards are complied with, in particular
   - the ILO core labour standards
   - the general principles and operational guidelines for fair recruitment
   - the UN Guiding Principles on Business and Human Rights
   - the international UN human rights conventions
4. the employer pays principle applies throughout the entire service process, i.e. the employer is obliged to cover all costs incurred in the recruitment process, language training and integration, the recognition procedure and all examination and application fees. Candidates may not be charged for recruitment services.
5. candidates are protected from commitment and repayment obligations and Transcura undertakes to
   - to waive any commitment and repayment obligations in the placement contracts with the nursing professionals, taking into account the permitted exceptions
   - not to place candidates in employment contracts that contain commitment and repayment obligations relating to the costs of the placement
6. IRIS standards are applied to promote ethical and fair recruitment.

Responsibility

Transcura's management and division heads are responsible for the implementation of this policy statement. This ensures that every employee in all areas of the company is aware of their own responsibility for our ethical recruitment and placement practices.

Risk management and risk controlling processes

Due to the general duty of care of "proper management", there is a de facto obligation to establish risk management measures in Transcura. The management of Transcura must ensure a proper business organisation with appropriate risk management and establish adequate risk management and risk controlling processes that ensure the identification, assessment, management, monitoring and communication of material risks. The risk management and risk controlling processes must ensure that the material risks can be recognised at an early stage, fully recorded and presented in an appropriate manner.

Transcura's risk management and risk controlling process includes all strategic and operational activities for the systematic handling of risks. Strategic activities include risk identification and risk assessment. Operational activities, on the other hand, include risk measurement, risk reporting, risk management as a consequence of assessment, measurement and reporting, as well as monitoring and controlling the success of the management measures. The company sees the risk management and risk controlling process as a permanent, continuous process.

The risk management organisation describes all organisational regulations and responsibilities for the risk management system. The company's risk management system comprises the early warning system, risk controlling and internal monitoring.

Dealing with risks in the recruitment and placement process

To ensure compliance with fair and ethical recruitment and placement practices, Transcura has implemented due diligence processes as components of its organisation and in its relationships with business partners.

A quality management officer has been appointed for this purpose, who also monitors compliance with fair and ethical recruitment and placement processes as part of the risk management system.

Transcura has the following instruments at its disposal for this purpose: