Siemens 2009 Annual Report Download - page 147

59
 Managing Board statements, Independent auditors’ report, Additional information
95 Net assets position 97 Report on post-balance sheet date events
98 Risk report
108 Information required pursuant to
§315 (4) HGB of the German Commercial
Code and explanatory report
114 Compensation report
114 Report on expected developments
Compliance
In the past, compliance was not sufficiently integrated in our
business practices, contrary to the existing internal regula-
tions. We introduced a Compliance program aimed to ensure
that our business practices are in full compliance with the law
and our own internal rules, and to enable us to better identify
and penalize compliance violations. We are convinced that
compliance also pays off economically. Our Compliance pro-
gram is based on three pillars prevention, detection and re-
sponse.
Consistently communicated clear rules shall prevent compli-
ance 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 com-
pliance 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 pro-
grams:
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 com-
pliance officer in charge of their unit. The following table
shows the number of inquiries submitted to the “Ask us” help
desk.
We measure the effectiveness of our prevention training activi-
ties through regular employee surveys. The results of these
surveys also form an element of our 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 other channels for reporting complaints
within Siemens. Both employees and third parties can report
violations of external and internal rules to the ombudsman or
the help desk. 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:
In fiscal 2009, 439 of these incidents were substantiated and
126 were unsubstantiated. In fiscal 2008, the number of sub-
stantiated incidents was 338 and unsubstantiated incidents
were 201.
Our third pillar, respond, includes rigorous and appropriate
measures in cases of substantiated compliance violations.
To strengthen our compliance efforts, we substantially in-
creased our compliance staff worldwide from 86 at the end of
fiscal 2006 to 170 at the end of fiscal 2007 and to 621, at the end
of fiscal 2008 including project employees that were involved
in rolling out our compliance programs. At the end of fiscal
2009, our compliance staff worldwide was 598.
In 2009, Siemens was again rated best in class by the Dow
Jones Sustainability World Index (DJSI) regarding the two as-
sessment categories Compliance and Risk Management. In the
current period, we expanded our leading position and received
the highest points possible in each category.
Participants in compliance trainings (in thousands)
Cumulative number of parti-
cipants in web-based training
140
123
Cumulative number of parti-
cipants in in-person training
79
52
FY 2009 FY 2008
B25G018_E
Inquiries submitted to the “Ask us” help desk
FY 2009 3,992
FY  3,836
B25G019_E
Incidents reported to “Tell us” help desk and ombudsman
FY 2009 565
FY  539
B25G020_E