Siemens 2007 Annual Report Download - page 90

90 Corporate Governance Report: Compliance Report
The compliance functions within the Company have been reorganized. Besides be-
ing responsible for overseeing compliance investigations, the new Corporate Com-
pliance Organization headed by the Chief Compliance Offi cer is primarily tasked
with the avoidance of violations. The aim is to continually improve the Compliance
Program and implement it Company-wide. Implementation of the Compliance Pro-
gram is handled by compliance offi cers in each of the Company’s Groups and more
than 80 Regional Companies, who are responsible for implementing the Compliance
Program in their respective areas, supported by other compliance staff. As of Octo-
ber 1, 2007, the Group Compliance Offi cers and – subject to local laws – the Regional
Compliance Offi cers are embedded in the Chief Compliance Offi cer’s personnel
organization.
Legal compliance consulting services fall under the responsibility of a department
comprising specialized lawyers. These lawyers from Compliance/Legal are responsi-
ble worldwide for all signifi cant investigations under criminal and administrative
law and safeguard the Company’s interests.
Effective October 1, 2007, all Company audit functions were merged into the Corpo-
rate Finance Audit unit headed by the Chief Audit Offi cer.
In December 2006, the Company – in connection with the allegations of corruption –
retained Debevoise & Plimpton LLP (Debevoise & Plimpton), an independent external
law fi rm, to clarify the circumstances relating to the criminal allegations at Com, to
analyze the implications of current fi ndings for the effi ciency of the Company’s com-
pliance system and its internal control system, and to investigate whether similar
situations have arisen at any other Siemens Group. Debevoise & Plimpton, on their
part, have commissioned independent auditors to support them in the examination
of Siemens’ control systems by providing forensic accounting experts. Debevoise &
Plimpton report regularly on the current status and future activities of their investi-
gation directly and exclusively to the Compliance Committee of the Supervisory
Board. For further details, see below (p. 165).
In response to the corruption charges, the Company also engaged an independent
compliance advisor in order to consult the Managing Board and the Compliance
Committee of the Supervisory Board and provide periodic status reports to them.
In addition to the compliance organization, the Company’s audit department and an
internal task force have been instructed to continue their examination of our com-
pliance and internal control system for gaps and any possibilities of circumvention.
In the process, they will take measures to correct defi ciencies or weaknesses in inter-
nal controls in selected local regions.