Siemens 2011 Annual Report Download - page 133

51 C. Combined management’s discussion and analysis 273 E. Additional information 153 D. Consolidated Financial Statements

At Siemens, compliance means that wherever we do busi-
ness, we adhere to the law and our own internal regulations –
above all, our Business Conduct Guidelines. This understand-
ing is a key element of integrity and an inseparable part of our
business activities. We do everything we can to prevent cor-
ruption and violations of the principles of fair competition
and to detect and punish misconduct. Our Compliance System
instills a permanent awareness of this responsibility in all our
managers and employees.
In his foreword to the Siemens Business Conduct Guidelines,
President and CEO Peter Löscher defines the role of the Guide-
lines this way: “They set out how we meet our ethical and legal
responsibility as a company and give expression to our corpo-
rate values of being responsible – excellent – innovative.”
Siemens is fully committed to compliance with the law and all
anti-corruption statutes. The Business Conduct Guidelines –
the centerpiece of our Compliance System – are absolutely
clear on this point: no corruption of any kind will be tolerated
at Siemens. We actively support the ratification and enact-
ment of the United Nations Convention against Corruption,
which, together with the UN Global Compact’s principles, pro-
vides important guidance for our entire organization.
Adherence to the law and to internal Siemens regulations –
this is the foundation of all our business activities. Viewed in
this light, compliance as we understand it is not a program
but the way we do business and uphold integrity.
Headed by the Chief Compliance Officer and the Chief Coun-
sel Compliance, our Compliance Organization promotes com-
pliance Siemens-wide – in particular, our efforts to prevent,
detect and respond rigorously to corruption and anti-trust vi-
olations. The organization also supports Siemens units in
dealing with violations in other areas. Its responsibilities in-
clude conducting internal investigations, imposing disciplin-
ary sanctions and eliminating identified shortcomings.
B.. The Siemens Compliance System
Since launching our Compliance Program worldwide, we’ve
continued to further develop and enhance it. We’ve also made
compliance a permanent part of our business processes. Our
Compliance Program has evolved into an overarching compli-
ance management system.
B. Compliance report
The Siemens Compliance System
Management responsibility
Compliance risk management
Policies and procedures
Training and communication
Advice and support
Integration in personnel processes
Collective action
Prevent
Whistleblowing channels “Tell us”
and ombudsman
Compliance controls
Monitoring and compliance reviews
Compliance audits
Compliance investigations
Detect
Consequences for misconduct
Remediation
Global case tracking
Respond