Siemens 2011 Annual Report Download - page 174

6 A. To our shareholders
23 B. Corporate Governance 51 C. Combined management’s discussion and analysis
52 C. Business and operating environment
80 C.2 Fiscal  – Financial summary
83 C. Results of operations
101 C. Financial position
114 C. Net assets position
117 C. Overall assessment of the economic position
118 C. Report on post-balance sheet date events
119 C. Report on expected developments and
associated material opportunities and risks
135 C. Information required pursuant to Section  ()
and Section  () of the German Commercial
Code (HGB) and explanatory report

plicable laws and our own internal rules. To serve this pur-
pose, our compliance system includes three pillars: prevent,
detect and respond. We are continuously working on further
integrating compliance into our business activities, and on
strengthening our efforts in combating corruption, together
with other market participants and governmental organiza-
tions (collective action).
To measure perceptions related to compliance among Siemens
employees, we have continued conducting regular surveys of
the large majority of Siemens employees. Since fiscal ,
compliance perception forms a part of the annual Siemens
Global Engagement and Compliance Survey which has also
been conducted in the reporting period.
The “Ask us” help desk encourages our employees to ask their
compliance-related questions. Employees submitted 1,740 in-
quiries to the help desk in fiscal , a decline from , in
fiscal . We believe this is due to improvements made in
our processes and to increasing knowledge and understand-
ing of compliance policies and processes among Siemens
employees. Furthermore, all employees can pose questions
directly to the compliance officer responsible for their unit.
The “Tell us” help desk and the company ’s ombudsman are
two secured reporting channels that can be used by our em-
ployees and external stakeholders to report violations of ex-
ternal and internal rules. These reports are passed on to our
compliance organization. In the current fiscal year, the num-
ber of incidents reported to the “Tell us” help desk and the om-
budsman was , compared to  reported incidents a year
earlier. In fiscal ,  of these reports were initially plau-
sible and required further inquiries or investigations in order
to clarify the reported incidents. There were  such reports
in fiscal .
Furthermore, possible misbehavior may also be reported di-
rectly to the Compliance Organization, particularly to the
Compliance Officers in our individual company units. Our em-
ployees make use of this reporting channel. We perceive this
as an indication for the confidence placed in our Compliance
Organization.
On December , , Siemens launched a global US$ mil-
lion Siemens Integrity Initiative to support organizations and
projects that fight corruption and fraud through collective ac-
tion, education and training. This initiative is part of the World
Bank-Siemens AG comprehensive settlement of July , .
In the first funding round,  projects were selected. The relat-
ed funding contracts were all concluded in fiscal , and
had a total volume of US$. million.
On October , , the Company received the Year Three Re-
port from the Compliance Monitor Dr. Theo Waigel, whom
Siemens had engaged as part of the settlement reached with
U.S. authorities in December . During Year Three, the
Monitor evaluated the long-term sustainability of Siemens’
compliance program and its compliance risk assessment and
compliance program evaluation processes, in addition to risk-
based themes and the implementation of Year One and Year
Two recommendations. As was set forth in the Settlement
Agreement with the U.S. Securities and Exchange Commis-
sion (SEC) and the U.S. Department of Justice (DOJ), this Year
Three Report contains () an evaluation of the open recom-
mendations from the Year One and Year Two Reports and ()
some new recommendations reasonably designed to improve
the effectiveness of Siemens’ program for ensuring compli-
ance with anti-corruption laws, plus () again a certification
by the Compliance Monitor that the compliance program of
Siemens, including its policies and procedures, is reasonably
designed and implemented to detect and prevent violations
within Siemens of anti-corruption laws.
At the beginning of fiscal , we have launched a system of
four compliance priorities, to further develop and improve our
compliance system:
> We intend to optimize the effectiveness and efficiency of
the introduced and proven compliance processes and tools.
> We intend to base our compliance risks analyses more
closely on the specific circumstances of our respective busi-
ness areas. A deep understanding of risks enables us to tai-
lor our compliance system to mitigate risks with optimized
resources.
> We intend to establish compliance even more strongly as an
integral aspect of all our business activities.
> We intend to further intensify interaction with our internal
and external stakeholders, especially for the purpose of
combating corruption. For us this means acting on our val-
ues and complying with rules and regulations – and pro-
moting responsible business practices in our markets with
collective action and the Siemens Integrity Initiative.