Siemens 2013 Annual Report Download - page 128

92 A. To our Shareholders 117 B. Corporate Governance
118 B.1 Corporate Governance Report
124 B.2 Corporate Governance statement pursuant to
Section 289a of the German Commercial Code
(part of the Combined Management Report)
126 B.3 Compliance Report
129 B.4 Compensation Report
(part of the Combined Management Report)
148 B.5 Takeover-relevant information (pursuant to
Sections 289 para. 4 and 315 para. 4 of the
German Commercial Code) and explanatory report
(part of the Combined Management Report)

B. Compliance Report
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 com-
pliance: adherence to the law and to our own internal regula-
tions. We have zero tolerance for corruption and violations of
the principles of fair competition – and where they do occur,
we rigorously investigate. The fact that we uncovered com-
pliance violations in our Company in the past fiscal year is,
in our view, a validation that our compliance system was
designed properly and implemented effectively.
Our Business Conduct Guidelines are binding for all managers,
employees and Managing Board members worldwide. They
also apply to members of the Supervisory Board where relevant.
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. 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 – like
the ten principles of the United Nations Global Compact – pro-
vides important guidance for our entire organization. We’re
also actively involved in the Global Compact and engaged in a
variety of its local networks.
B.3.1 Compliance priorities
Since their introduction in fiscal 2011, our compliance priori-
ties have taken into account and fulfilled the continuously
evolving requirements in the field of compliance – require-
ments that reflect both our own work and the changing market
conditions and compliance risks of our business activities.
Each fiscal year, we focus our activities on the compliance
priorities that provide the basis for the ongoing development
of our compliance system. This approach has proven its worth.
B.3.2 Further information, indicators
and legal proceedings
For information on compliance risks, please see C. REPORT
ON EXPECTED DEVELOPMENTS AND ASSOCIATED MATERIAL OPPORTUNITIES
AND RISKS on pages 227-245 of this Annual Report. Detailed in-
formation on our compliance priorities for fiscal 2013 and fiscal
2014 and a list of our compliance indicators (with accompany-
ing notes) are set out in
C.. COMPLIANCE on pages 224-226.
We report on corruption and antitrust proceedings in
NOTE
 LEGAL PROCEEDINGS on pages 306-312.
On our website, you’ll find extensive information on compli-
ance at Siemens and an overview of the published Company
information on compliance within the structure of the guid-
ance by the Global Compact and Transparency International on
reporting for the Global Compact’s tenth principle – anti-corrup-
tion:
WWW.SIEMENS.COM/AR/ANTI-CORRUPTION-REPORTING-INDEX .
B.3.3 Compliance training
One focus of our preventive measures under the compliance
system is to provide training to all managers and employees who
hold positions with a particular risk profile. The Com pliance
Officers of the relevant Company units identify the managers
and employees whose participation is required and ensure
they attend the training seminars. They monitor and confirm
the fulfillment of these requirements at regular intervals.
The assessment and analysis of compliance risks for the oper-
ating units and at Group level
( C. REPORT ON EXPECTED DEVEL-
OPMENTS AND ASSOCIATED MATERIAL OPPORTUNITIES AND RISKS
) offers
important indicators that help us develop and define the focus
of our training activities, including the selection of the themed
modules for the annual events held in conjunction with the
Integrity Dialog, which we introduced Siemens-wide in fiscal
2013. Our operating units address specific challenges by
enhancing their training activities with additional topics from
their own businesses. In this way, the training reflects both
Siemens-wide topics and the key topics specific to the operat-
ing units.