Siemens 2008 Annual Report Download - page 126

30 Corporate Governance Report: Compliance Report
In scal 2008, the Company also initiated a quarterly, independent Compliance Review Process in the various
businesses and Regions. A corresponding review is also submitted quarterly to the Managing Board. In the
Compliance Review Process, important compliance issues are discussed, compliance risks are identied and
assessed, and measures to reduce them are presented.
Analyzing and remedying abuses
The U.S. law rm of Debevoise & Plimpton LLP continued its independent investigations in scal 2008 and the
Compliance Investigations department was established in May 2008. All in all, this department and Corporate
Finance Audit (CF A), which also handles compliance investigations, received 207 compliance complaints from
internal and external sources during the scal year. We completed 90 compliance investigations in the same
period.
At the end of October 2007, the Managing Board of Siemens AG launched an amnesty program offering
em ployees a way to voluntarily report violations of laws against corruption in the public sector. The program
aimed at supporting the independent investigations by Debevoise & Plimpton LLP and facilitating a complete
and timely clarication of suspected violations of anticorruption laws. During the program, which expired at
the end of February 2008, a total of 123 employees submitted amnesty requests. To date, 82 requests have been
granted.
In May 2008, the compliance organization also took over the processing of fraud cases. The total value of prop-
erty damage or loss recorded and pursued in scal 2008 amounted to over €16 million.
Raising risk awareness
An intensive training program was initiated by the Company to raise awareness of potential compliance risks
and inform employees about the basics of compliance rules and regulations. In scal 2008, the measures focused
on fair competition laws and ghting corruption. For example, all employees that had to sign a written commit-
ment to abide by our Business Conduct Guidelines also had to complete online training in anticor ruption and
fair competition laws. Over 120,000 employees had received such training by the end of September 2008.
In addition, starting in the second quarter, all employees working in so-called sensitive functions have been
receiving multi-hour group training. These are employees who may negotiate contracts with representatives or
ofcials of governments, public authorities and state-owned enterprises, or who might inuence such negotia-
tions. The key objective here is to provide employees with a working knowledge of international anticorruption
laws and regulations and the related Siemens guidelines. Local laws and regulations in the various Regions are
also included in the training. Emphasis is placed on the discussion and solution of case studies. Since the pro-
gram began in January 2008, over 50,000 employees have attended these training sessions.
In scal 2008, members of the Managing Board and the Chief Compliance Ofcer discussed the importance of
compliance and explained Company management’s attitude at various management conferences and employee
meetings in more than 50 countries.