Siemens 2008 Annual Report Download - page 193

Management’s discussion and analysis 97
Consistently communicated clear rules shall prevent compliance violations. These rules include our business
conduct guidelines, which obligate management and employees to obey the law and our internal regulations.
We also train our employees with regard to corruption and other legal compliance issues. We offer both web-
based training and in-person training. The following table shows the cumulative number of employees who
participated in both types of training programs:
We also established a compliance help desk with an “ask us” function that encourages employees to ask their
compliance questions. All employees can also pose questions to the compliance ofcer in charge of their unit.
The following table shows the number of inquiries submitted to the “ask us” help desk, which we launched in
September 2007:
We measure the effectiveness of our prevention training activities through regular employee surveys. The
results of these surveys also form an element of our compliance incentive system for top management.
The second pillar of our compliance program, detect, includes an independent ombudsman and a “tell us” help
desk. These supplement our existing channels for reporting complaints within Siemens. Both employees and
third parties can report violations of external and internal rules to the ombudsman or the helpdesk. These
reports are passed on to our compliance organization. The number of incidents reported to the “tell us” help
desk and the ombudsman was as follows:
Our third pillar, respond, includes rigorous and appropriate measures in cases of compliance violations.
To strengthen our compliance efforts, we substantially increased our compliance staff worldwide from 86 at the
end of scal 2006 to 170 at the end of scal 2007 and to 621 at the end of scal 2008 (including project staff for
implementing compliance programs).
Year ended
September 30,
(in thousands) 2008 2007
Cumulative number of participants in web based training 123 31
Cumulative number of participants in in-person training 52 1
Year ended
September 30,
2008 2007*
Inquiries submitted to the compliance “ask us” help desk 3,836 198
* The “ask us” help desk started in September, 2007, thus the number for scal 2007 includes inquiries for only one month.
Year ended
September 30,
2008 2007*
Incidents reported to helpdesk “tell us” and ombudsman 539 156
Thereof substantiated 338 67
Thereof unsubstantiated 201 89
* The helpdesk “tell us” started in August, 2007.