Siemens 2007 Annual Report Download - page 89

Corporate Governance Report: Compliance Report 89
¢ The Company introduced a new guideline regarding anti-public corruption
compliance.
¢ The Company implemented new Company-wide policies regarding “Retention of
intermediaries who interact with the government on Siemens’ behalf,” “Com-
pliance in M&A transactions, joint ventures and minority investments” and “Gifts
and hospitality.”
¢ To improve its internal controls, the Company implemented a centralization of its
payment and cash management systems.
All corruption-related internal regulations were summarized into an easy-to-read
“Siemens Anticorruption Compliance Guide” and distributed to selected employees.
Furthermore, the Company established a Corporate Disciplinary Committee to con-
sider and impose appropriate disciplinary measures in cases where suspicions of
violations of law or Company policies or other misconduct have been substantiated.
Structure and functions of the compliance organization
The Managing and Supervisory Boards view the Compliance Program as an essential
element of Siemens’ management and control structure. The compliance organiza-
tion that was introduced in 2001 as part of the worldwide implementation of the
Compliance Program has been restructured to refl ect its new uniform and consistent
profi le and personnel realignment.
The Supervisory Board formed a Compliance Committee chaired by the Chairman
of the Supervisory Board. For further information on the composition and mandate
of the Compliance Committee see above (page 82).
At the beginning of fi scal year 2008, the Company established a new Managing
Board position for legal and compliance matters. Peter Y. Solmssen was appointed to
the Managing Board and named General Counsel, overseeing responsibility for legal
and compliance issues.
Effective September 19, 2007, the Managing Board appointed a new Chief Compli-
ance Offi cer to serve in the legal and compliance unit. In addition, he will report to
the CEO and President of the Managing Board as well as to the Compliance Commit-
tee and the Audit Committee of the Supervisory Board.