Siemens 2009 Annual Report Download - page 113

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 Managing Board statements, Independent auditors’ report, Additional information
Avoiding compliance risks
In January 2009, the Managing Board of Siemens AG adopted
and brought into force the revised Business Conduct Guide-
lines. In the new Guidelines, we have significantly extended
the rules for fighting corruption and ensuring fair competition
and, among other things, amended the provisions relating to
prevention of money laundering, dealing with trade controls
and requirements for our suppliers. In addition, a pledge to
comply with the ten principles of the UN Global Compact has
been incorporated into the revised version of the Business
Conduct Guidelines.
The introduction of the compliance control system focusing on
the fight against corruption was completed in fiscal 2009. To
further improve the compliance program and adjust it to
guideline amendments, processes and new instruments, we
have developed an extended Compliance Control Framework
(CCF), also taking into account feedback from our employees
resulting from the survey on compliance and from other
sources.
In fiscal 2008, we integrated a component for the assessment
of corruption risks into our IT-based LoA (Limits of Authority)
process for approval of customer projects, in particular for
public-sector customers, and in fiscal 2009 we adjusted the
process to accommodate the organizational changes within
the Company. From the introduction of the process to the end
of fiscal 2009, more than 45,000 participants completed a
web-based training program on the process. In fiscal 2009, we
also promoted the use of a tool to check the integrity of busi-
ness partners who act as intermediaries between Siemens and
final customers (Business Partner Compliance Due Diligence
Tool) by means of web-based and face-to-face training ses-
sions. The tool was introduced at the end of July 2008.
Compliance as a management task
Compliance responsibility rests with management. The com-
pliance review process in the various businesses and Regions
that was further expanded in fiscal 2009 involves not only
quarterly reports to the Managing Board and the Supervisory
Board, but also the discussion of important compliance issues
as part of general management meetings and the develop-
ment of improvement measures at all levels of the Siemens or-
ganization. This will help establish compliance as an integral
and permanent element on the Company’s management
agenda.
Also with a view to strengthening management’s compliance
responsibility, compliance has been an integral part of the bo-
nus system for top executives since 2008. The variable com-
pensation of senior management for fiscal 2009 also includes
a compliance component which, as in fiscal 2008, is based on
the results of the worldwide employee compliance awareness
survey, in addition to other criteria.
In June 2009, we conducted a second anonymous survey of
approximately 90,000 randomly selected employees world-
wide to once again assess their awareness of compliance and
integrity issues and receive critical feedback. The survey re-
sponse rate, at 47 percent, was up from last year’s survey,
which shows that these issues continue to have high priority
among our employees. When analyzing this year’s survey, we
are able for the first time to determine and evaluate changes
year-on-year. As in the fiscal 2008, we will use this year’s sur-
vey results to identify specific opportunities for improvement.
The management of the respective Company units will report
on their implementation in compliance reviews.