Siemens 2007 Annual Report Download - page 91

Corporate Governance Report: Compliance Report 91
Complaints, comments and questions
As required by the SOA rules, procedures for the receipt, retention and treatment of
potential complaints regarding accounting practices as well as procedures for hand-
ling relevant reports from specifi c attorneys (internal and external) have been im-
plemented. Such complaints and comments, including those submitted anonymous-
ly, are processed by the Chief Compliance Offi cer, in the case of complaints related
to accounting practices, and by the General Counsel in the case of reports from spe-
cifi c attorneys.
In addition to the existing internal procedures for reporting and handling com-
plaints, an external attorney has been engaged to act as an independent ombuds-
man to provide a new protected communication channel for Siemens employees and
third parties.
Since September 2007, our customers, suppliers, business partners and employees
worldwide have been offered the opportunity to submit reports on violations to the
“Tell us” Compliance Helpdesk, either by telephone or online 24/7. The external pro-
vider specializes in the secure and confi dential handling of sensitive information.
In addition, the Company encourages employees to use a centralized question-and-
answer platform. The “Ask us” Compliance Helpdesk provides employees with an
opportunity to ask questions on compliance-relevant topics. This relates both to the
application of compliance-relevant regulations in the day-to-day business and the
understanding of requirements for agreements with external partners.
Training
In order to avoid irregular business practices, the Company places great importance
on thorough training. During the period from February to October 2007, some 1,400
Siemens executives were trained worldwide as part of a comprehensive training pro-
gram. The training sessions focused on the fi ght against corruption and antitrust
laws. Other training activities included concrete Company instructions concerning,
for example, payment and accounting transactions, the treatment of gifts and hospi-
tality, and the retention of intermediaries and consultants.
Furthermore, the Company introduced a web-based Company-wide training system
with comparable training quality that will be used by up to 100,000 employees. To
date, some 36,000 employees have participated in this additional training program.
Conferences and other events are organized by the compliance offi cers in order to
help ensure that Company management’s directions are uniformly communicated
and implemented worldwide. As part of this approach, all of the nearly 100 Group
and Regional Compliance Offi cers were familiarized with the realigned organization
and content of the Siemens Compliance System at several-day conferences in March
and October 2007.