Siemens 2007 Annual Report Download - page 88

88 Corporate Governance Report: Compliance Report
Compliance Report
Compliance at Siemens is based on directions from Company
management. Compliance with legal and regulatory require-
ments and in-house guidelines is an essential element of the
Company’s management and corporate culture.
Internal regulations – Business Conduct Guidelines and Code of Ethics
Our Business Conduct Guidelines and our Code of Ethics for Financial Matters form
the basis of our Compliance Program.
The Business Conduct Guidelines, introduced by the Managing Board in 2001, con-
tain binding standards for law-abiding behavior and precise rules regarding, among
other things, compliance with applicable fair competition and anticorruption laws,
handling of donations and gifts, avoidance of confl icts of interest, prohibition of
insider trading, and protection of Company assets. They also specify procedures
for dealing with complaints. The Business Conduct Guidelines are binding on all
Company employees and Managing Board members worldwide. The members of
our Supervisory Board also comply with these Guidelines where applicable.
Furthermore, in 2003 the Managing Board and the Supervisory Board implemented
a Code of Ethics for Financial Matters, as required by the SOA rules. Both the Busi-
ness Conduct Guidelines and the Code of Ethics for Financial Matters are available
on our Internet website.
The Business Conduct Guidelines and the Code of Ethics for Financial Matters are
complemented by numerous other regulations that are applicable Company-wide.
All regulations are regularly updated.
In response to the allegations of corruption against certain employees of the Com-
pany that became known at the end of 2006 (for details, see “Management’s Discus-
sion and Analysis – Legal Proceedings”), Siemens has taken a number of important
steps over the last twelve months to improve its compliance and internal control
system. The Compliance Program was restructured to emphasize the key points
Prevent, Detect and Respond.
Among other measures, Siemens introduced a number of new internal regulations:
¢ The Company implemented a moratorium on entering into new Business Consul-
tant Agreements (BCAs) as well as new payments under existing BCAs. Any excep-
tions require the prior written consent of relevant senior management as well as
the written consent of the Company’s Chief Compliance Offi cer, based on a review
of the agreements in questions. As part of this policy, the Company will review, on
an ongoing basis, the existing BCAs for compliance risks in connection with their
continued performance. In certain cases, the Company terminated BCAs.