Siemens 2012 Annual Report Download - page 119

49 C. Combined Management Report 239 E. Additional Information 135 D. Consolidated Financial Statements

For Siemens, promoting integrity means acting in accordance
with our values – responsible, excellent and innovative –
wherever we do business. A key element of integrity is compli-
ance, which means for us: adherence to the law and to our
own internal regulations. We have zero tolerance for corrup-
tion and violations of the principles of fair competition. Pre-
venting misconduct before it occurs is our primary goal. When
we can’t prevent wrongdoing in individual cases, we investi-
gate and take rigorous disciplinary action irrespective of the
people involved or their positions.
Our Business Conduct Guidelines describe how we fulfill our
compliance-related responsibilities. They’re also an expression
of our values and lay the foundation for our own internal regu-
lations. For us, compliance is not just a program but the way
we do business and uphold integrity at our Company. Our
compliance system instills a permanent awareness of these
responsibilities in all our managers and employees. We actively
support the ratification and enactment of the United Nations
Convention against Corruption, which provides important
guidance for our entire organization.
.. Our compliance priorities
In fiscal 2011, we focused our compliance activities on four
priorities that provide the basis for the ongoing development of
our compliance system. This approach has proven its worth.
Our
compliance priorities take into account and fulfill the
continu-
ously
evolving requirements in the field of compliance – require-
ments that are the result of our own compliance work, on the
one hand, and of changing market conditions, on the other.
We’ve revised our compliance priorities for fiscal :
> Stand for integrity
> Committed to business
> Manage risk and assurance
> Focus on efficiency
The following topics will also be the focus of our activities in
fiscal .
.. Integrity dialogue – Communica-
tion between managers and employees
We keep managers and employees in areas with high risk pro-
files up to date on the latest compliance requirements. This is
an established and key element of our preventive measures.
For us, strengthening our managers’ personal responsibility
for compliance is vital. That’s why we strive to ensure their
commitment to our compliance goals and help them foster
integrity visibly and energetically.
The principle is simple. First, Compliance Officers train the top
managers in their respective units. These managers then train
their immediate subordinates, who, in turn, train those under
them. This compliance training is integrated into already
scheduled meetings and personal discussions and, thus, in-
creases the importance of dialogue between managers and
their teams. Business units select the training materials from a
catalogue of modules that’s available Company-wide and sup-
plement these with specific compliance-related topics relevant
for their own businesses.
.  
   
Management responsibility
> Compliance risk management
> Policies and procedures
> Training and communication
> Advice and support
> Integration in personnel processes
> Collective action
> Whistleblowing channels “Tell us”
and ombudsman
> Compliance controls
> Monitoring and compliance reviews
> Compliance audits
> Compliance investigations
> Consequences for misconduct
> Remediation
> Global case tracking
Prevent Detect Respond