Siemens 2010 Annual Report Download - page 98

6 To our shareholders 21 Corporate Governance
23 Corporate Governance report
29 Corporate Governance statement pursuant to §a
of the German commercial code (HGB) (part of the
“Combined management’s discussion and analysis”)
30 Compliance report
34 Compensation report (part of Notes to
Consolidated Financial Statements)
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COLLECTIVE ACTION AND
THE SIEMENS INTEGRITY INITIATIVE
We’ve been committed to collective action – the cooperation of
companies and other organizations to ensure ethical business
practices – in numerous markets for several years. We’ve inten-
sified this commitment through memberships in organizations
like the International Business Leaders Forum (IBLF) and the
Anti-Corruption Initiative of the World Economic Forum. We’ve
been a member of the anti-corruption working group of the UN
Global Compact for three years. Most recently, we participated
– together with Transparency International – in the drafting of
the Global Compact’s guidelines for anti-corruption reporting
and for combating corruption in supply chains.
Corruption is a complex problem. That’s why collective action
to combat it must be implemented step-by-step at multiple
levels. The first step is to strengthen legal systems and the
enforcement of national laws. Concrete integrity agreements
and binding codes of conduct generally require intensive
preparation in the form of training activities, the establish-
ment of platforms for dialogue and the involvement of busi-
ness associations and federations.
The launch of the Corporate Ethics Initiative in April 2010 was
an important milestone in our collective action activities. We
– together with other companies and institutions – had been
supporting efforts to establish this initiative, which aims to
promote ethical business practices in Russia, ever since joining
the IBLF in 2009. We’re one of the initiative’s 46 founding
members, most of whom are multinational corporations head-
quartered in Germany.
We’ve also launched a worldwide Siemens Integrity Initiative,
with a budget of US$100 million. The initiative, which is part
of our July 2009 settlement with the World Bank, supports or-
ganizations and projects that promote ethical markets and fair
competition by combating corruption and fraud through col-
lective action and training and continuing education mea-
sures. We’re dispensing funds in three selection rounds ex-
tending over 15 years. The first round, with a planned funding
volume of some US$40 million, began on December 9, 2009 –
International Anti-Corruption Day.
About 300 organizations and projects from 66 countries ap-
plied to take part in our Integrity Initiative. Sixty-three percent
of the applications involved collective action projects and
37 percent education and training projects. Some of the appli-
Compliance priorities for further developing anti-corruption and anti-trust activities at our Company
Improving compliance processes
Protecting Siemens’ reputation for compliance
Improving compliance risk analyses
Bringing compliance closer to our business
> Integration with personnel
processes
Prevent
> Tone from the top
> Helpdesk (including global ombudsman)
> Compliance Organization
The Siemens Compliance Program
> Training
> Policies and
procedures / tools
> Program
communication
> Centralization
> Compliance
investigations
> Compliance
reviews
> Compliance
controls
> Consequences for misconduct
> Global case tracking
> Monitoring effectiveness
Detect Respond
>
>
>
Continuous
improvement