Siemens 2012 Annual Report Download - page 120

1 A. To our Shareholders 21 B. Corporate Governance
22 B. Corporate Governance Report
28 B. Corporate Governance statement pursuant to
Section a of the German Commercial Code
(part of the Combined Management Report)
29 B. Compliance Report
31 B. Compensation Report
(part of the Combined Management Report)
44 B. Takeover-relevant information (pursuant to
Sections  para.  and  para.  of the
German Commercial Code) and explanatory report
(part of the Combined Management Report)

.. Collective action – Supporting
business success through fair competition
Siemens promotes ethical business practices and fair competi-
tion beyond Company boundaries – this, too, is one of our key
compliance priorities.
Going it alone can have only a limited impact in the fight
against corruption. If real progress is to be made, as many
stakeholders as possible must act in concert. That’s why we’ve
joined forces with other organizations to combat corruption
and promote ethical markets through collective action and
through the Siemens Integrity Initiative.
Now that we’ve established collective action throughout the
Company and involved a large number of our business units
engaging with numerous partners in its implementation, we
plan to focus our collective action activities in fiscal  on
our particular business requirements more intensively than in
the past. There are many ways to do this. For example, future
CRAs can increase the emphasis on defining collective action
measures such as fair competition partnerships between bid-
ders for large contracts or the voluntary self-commitment of
industry federations to compliance standards that reduce com-
pliance-related risks. As in the other areas described, close and
trust-based cooperation between Compliance Officers, sales
personnel and managers will play a key role here in identifying
appropriate measures.
The further development of our compliance system entails
continuously adapting it to the evolving requirements in the
field of compliance. Our overall aim remains unchanged: we
want to anchor compliance permanently throughout our glob-
al Company in order to ensure that we continue making sound
business decisions based on clear principles of integrity.
To learn more, please see:
 ...     
../
We’ll begin introducing our integrity dialogues Company-wide
in fiscal . Compliance Officers will support managers
throughout the process. They’ll also support the business units
in selecting the employees for whom participation in com pliance
training programs and integrity dialogues is obligatory. Man-
agers will select participants on the basis of Company-wide
regulations, taking into account, among other things, the re-
sults of compliance risk assessments (CRAs) – a process that
will enhance both management responsibility for compliance
and the business-specific and risk-related orientation and effi-
ciency of our entire compliance system.
.. Compliance risk assessments
at business units
Initiating effective measures to detect and minimize com-
pliance-related risks in business operations at an early stage is
the heart of a successful compliance system. Our assessment
and monitoring processes are being further improved by our
CRAs. In use since the beginning of fiscal , the CRA pro-
cess improves the links between compliance and business
operations at Siemens.
Every year, the CEOs of our business units meet with other key
managers and the relevant Compliance Officers to systemati-
cally determine the compliance-related risks at their respective
units. The compliance-related risks identified in the process
are then assessed and measures for reducing them defined.
The resulting analyses are incorporated into the Company-
wide compliance risk analysis, which covers the material com-
pliance-related risks for Siemens as a whole.
The accurate assessment of compliance-related risks depends
on close and trust-based cooperation between the managers
and specialists at our business units, on the one hand, and our
Compliance Officers, on the other.