Siemens 2009 Annual Report Download - page 114

26
 Reports Supervisory Board /
Managing Board  Corporate Governance  Management’s discussion and analysis  Consolidated Financial Statements
16 Corporate Governance report 24 Compliance report 28 Compensation report (part of Notes
to Consolidated Financial Statements)
www.siemens.com/compliance
www.siemens.com/corporate-governance
have been personally trained in the relevant functions in face-
to-face training sessions. Employees new to these functions
have been included in both types of training.
The web-based training in anticorruption and fair competition
laws, for example, was mandatory for all employees who had
signed a written commitment to abide by our Business Con-
duct Guidelines. The training aimed at increasing our employ-
ees’ awareness of compliance risks and providing them with a
basic understanding of compliance requirements. These also
include important foreign laws and international agreements.
In September 2009, we started a new web-based training pro-
gram to familiarize employees with the revised Siemens Busi-
ness Conduct Guidelines: discussion of compliance challenges
and fictitious case studies are designed to increase under-
standing of the new guidelines. This training course is manda-
tory for key executives and other employees authorized to
sign. The program will be available in German, English and
14 other languages.
Since the second quarter of fiscal 2008, all employees working
in so-called sensitive functions have been receiving hours of
classroom training. This training program is mandatory for
employees who are authorized to negotiate contracts with
representatives or officials of governments, public authorities
and state-owned enterprises, or who might influence such ne-
gotiations. 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 covered in this
training program. In 2009, we started refresher courses for
employees whose training dates back more than one year.
In fiscal 2009, two new processes helped us to further develop
our compliance framework and improve its handling: We inte-
grated the existing rules regarding gifts, gratuities and hospi-
tality into an IT-based process called the “Approve it” compli-
ance help desk, which allows employees to personally check
by means of a country-specific evaluation sheet whether ap-
proval is required or, in the event of complex issues, to request
a review by the relevant compliance officer. Donations, mem-
berships and sponsoring are now recorded, evaluated and ap-
proved Company-wide in accordance with clear and uniform
compliance criteria, using a new, likewise electronic process.
Detecting and remedying abuses
In fiscal 2009, a total of 565 (2008: 539) incidents and concerns
about possible improprieties were reported to the independent
ombudsman and the “Tell us” compliance help desk, 439
(2008: 338) of which justified an initial suspicion that was pur-
sued internally. Examinations by our Corporate Finance Audit
unit produced additional findings.
In the year under review, we handled a total of 784 (2008: 909)
compliance-related violations involving employees. The inves-
tigations of concerns about possible misconduct not only as-
sist in addressing abuses but also help us identify and analyze
possible deficits. The implementation of the required improve-
ment measures is reviewed upon the close of each investiga-
tion.
Providing knowhow and experience
In fiscal 2009, we completed the Company-wide special anti-
corruption training program for key executives and other em-
ployees that had been started a year earlier. Since the begin-
ning of the training program, around 140,000 employees have
completed online training, while around 79,000 employees