Siemens 2012 Annual Report Download - page 200

1 A. To our Shareholders
21 B. Corporate Governance 49 C. Combined Management Report
50 C. Business and economic environment
64 C. Financial performance measures
69 C. Results of operations
82 C. Financial position
93 C. Net assets position
95 C. Overall assessment of the economic position
96 C. Subsequent events
97 C. Sustainability
111 C. Report on expected developments and
associated material opportunities and risks

compliance perception forms a part of the annual Siemens
Global Engagement 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 , in-
quiries to the help desk in fiscal . We believe the decline
from , inquiries in fiscal  is due to improvements made
in our processes and to increasing knowledge and understand-
ing of compliance policies and processes among Siemens em-
ployees. Furthermore, all employees can pose questions direct-
ly 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 employees
and external stakeholders to report violations of external and
internal rules. These reports are passed on to our compliance
organization. In fiscal , the number of incidents reported
to the Tell us help desk and the ombudsman was , of these
 were initially plausible and required further inquiries or in-
vestigations in order to clarify the reported incidents.
Furthermore, possible misbehavior may also be reported di-
rectly to the Compliance Organization, particularly to the Com-
pliance Officers in our individual company units. Our employ-
ees make regularly use of this reporting channel. We perceive
this as an indication of the confidence they place in our Com-
pliance Organization.
On December , , Siemens launched a global US$ mil-
lion Siemens Integrity Initiative to support organizations and
projects that fight corruption and fraud through Collective Ac-
tion, education and training. This initiative is part of the World
Bank Siemens AG comprehensive settlement of July , .
The status of the  projects funded within the first funding
round with a total contractual funding volume of US$. mil-
lion was presented to the World Bank in March , based on
the first annual report on the Siemens Integrity Initiative
which is online publicly available.
On October , , the Company received the Year Four
Report from the Compliance Monitor Dr. Theodor Waigel,
whom Siemens had engaged as part of the settlement reached
with U.S. authorities in December . During Year Four, 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 Two and Year
Three recommendations. As was set forth in the Settlement
Agreement with the U.S. Securities and Exchange Commission
(SEC) and the U.S. Department of Justice (DOJ), this Year Four
Report contains () an evaluation of the open recommenda-
tions from the Year Two and Year Three Reports 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. The Year
Four report also states that all recommendations from Year
Two and Year Three reports are fully implemented. Since the
Year Four Report does not include any new recommendations,
this means that all recommendations of the Monitor are fully
implemented. As was set forth in the aforementioned settle-
ment, the Monitorship ends four years after the settlement
date on December , .
At the beginning of fiscal , we have launched a system of
four compliance priorities to further develop and improve our
compliance system. The compliance priorities have guided our
activities in fiscal . These included initial implementation
of a new compliance risk assessment covering all Siemens en-
tities, which the Sectors, Divisions and Clusters as well as
cross-sector businesses are required to perform on a regular
basis, and the development and roll out of a new anti-trust
compliance program.
Effective from fiscal  we have updated the compliance
priorities as follows:
    
Compliance priorities
Our aim is to further encourage
business management respon-
si bility for compliance and to
continue promoting responsible
business practices in our markets
with Collective Action and
the Siemens Integrity Initiative.
We want to leverage the
Compliance system to support
sustainable growth and
as a competitive advantage.
We continue to develop the
com pliance risk management
and to provide reliable assurance
for our business entities.
We focus on increasing the effi-
ciency of compliance operations
and collaboration.
Stand for Integrity Committed to Business Manage Risk & Assurance Focus on Efficiency