Siemens 2010 Annual Report Download - page 97

147 Consolidated Financial Statements 49 Combined management’s discussion and analysis 261 Additional information
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STANDING UP FOR INTEGRITY
Our decisions and our conduct must always be rooted in integ-
rity. That is, they must always comply with moral principles
and our own Company values. We measure ourselves by how
well we achieve this goal. And we expect our stakeholders to
measure us by the same yardstick. Compliance – adherence to
the laws of the countries in which we do business, to our own
internal regulations and, above all, to our Business Conduct
Guidelines – is a key element of integrity and an inseparable
part of our business activities. Therefore, we must play a criti-
cal and pioneering role in preventing corruption and violations
of the principles of fair competition and in the rigorous detec-
tion and punishment of misconduct. Our Compliance Program
is designed to permanently instill an awareness of this respon-
sibility in all our managers and employees.
Siemens has committed itself fully and explicitly to compliance
with the law and all anti-corruption statutes. Our Business
Conduct Guidelines, which are the heart of our Compliance
Program, are absolutely clear on this point: no corruption of
any kind will be tolerated at Siemens. In addition, we’re ac-
tively supporting the ratification and enactment of the
Anti-Corruption Convention of the United Nations, which,
alongside the UN Global Compact, provides important guid-
ance for our Company.
The Siemens Compliance Organization drives compliance
Company-wide – in particular, our efforts to prevent, detect
and respond to corruption and anti-trust violations. The orga-
nization also supports our Company units in dealing with in-
tentional violations in other areas. Its responsibilities include
conducting internal investigations, imposing disciplinary sanc-
tions and coordinating remedial action to correct identified
shortcomings. In fiscal 2010, we modified the Compliance Or-
ganization’s leadership structure. The Chief Compliance Officer
is now responsible for all operational and sales-related issues,
while the individual occupying the newly created position of
Chief Counsel Compliance is responsible for all legal aspects of
compliance. Effective July 1, 2010, the Company appointed
Josef Winter Chief Compliance Officer and Dr. Klaus Moos-
mayer Chief Counsel Compliance.
To implement improvements and respond to the changing
requirements of our businesses worldwide, the Siemens Com-
pliance Program must be continuously developed. For this
reason, it will never be “completed.” Instead, it’s best under-
stood as a comprehensive, long-term change management
process. Compliance will remain an ongoing, critical responsi-
bility at our Company. Within the context of our strategic
framework, the compliance management team has defined the
following medium-term priorities for the further development
of our anti-corruption and anti-trust activities:
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We want to maximize the effectiveness and efficiency of our
proven compliance processes and tools.
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Through compliance risk analyses, we want to take even
better account of the particular conditions at our various
businesses.
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We want to anchor compliance more firmly in business ac-
tivities Company-wide.
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To protect our reputation for compliance, we want to
strengthen the commitment of all our stakeholders to the
battle against corruption – in particular, through the
Siemens Integrity Initiative and our participation in collec-
tive action.