Siemens 2013 Annual Report Download - page 129

155 C. Combined Management Report 253 D. Consolidated Financial Statements 357 E. Additional Information
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B.. Employee survey on compliance
We conduct regular surveys to gauge how Siemens employees
perceive the topic of compliance. Since fiscal 2010, this has
been a
fixed component of the Company-wide Siemens Global
Engagement
Survey. The next survey is planned for fiscal 2014.
B.. Business partners and suppliers
All business partners who function as intermediaries between
Siemens and its customers must undergo standardized
Company-wide risk assessment before business relations com-
mence. Business partners are assigned a risk class based on cer-
tain risk indicators such as the risk of corruption in the local
country. The risk class determines how business relations –
license requirements, mandatory contract clauses, etc. – proceed.
In the year under review, we made our business partner check
more risk-oriented. We also provided all Siemens operating
units with standardized recommendations for the ongoing
monitoring of business partner activities.
Our Code of Conduct for Siemens suppliers requires our sup-
pliers to behave in a lawful manner generally and to comply
with our anti-corruption principles, in particular. This Code of
Conduct is based on the ten principles of the United Nations
Global Compact. We take a risk-based approach with system
checks and on-site inspections to monitor whether our sup-
pliers are in compliance with the Code’s requirements. For more
information, please see
C.. SUPPLY CHAIN MANAGEMENT on
page 215 of this Annual Report.
In fiscal 2013, we developed information and recommenda-
tions designed to help our employees deal with routine risks
from cor
ruption, fraud and embezzlement in the area of pur-
chasing. Here, we drew upon
our experience with a similar
guide to antitrust regulations, which we provided to employ-
ees as part of our antitrust compliance program.
B.. Siemens Integrity Initiative
If real progress is to be made in combating corruption and
fostering fair competition, as many stakeholders as possible
must act in concert. That’s why we’ve joined forces with
other organizations to fight corruption and promote ethical
markets through collective action and the Siemens Integrity
Initiative.
Siemens introduced the second funding round of the Siemens
Integrity Initiative on June 27, 2013. Information on the process
and a description of the selection criteria are published on our
corporate website at WWW.SIEMENS.COM/INTEGRITY- INITIATIVE.
Information on the projects supported in the first funding round
and their status can be found in the second annual report of
the Siemens Integrity Initiative, which is also available on our
corporate website.
B.. Transfer of responsibility
for data privacy
Fiscal 2014 will see the Siemens-wide transfer of operational
responsibility for data privacy to the compliance organization.
The related tasks include risk assessments, monitoring activi-
ties, training for all managers and employees and complaint
handling. The corporate legal department is providing legal
advice. We’re adapting our compliance system processes
accordingly – for example, by updating the compliance risk
assessment for our operating units to include data privacy.
The Siemens compliance organization has an active presence
with a firm foothold in our operating units. The Compliance
Officers work with the CEOs of the operating units, and our
employees contact their local Compliance Officer with any
questions or reports about possible misconduct. We’re now
applying this same efficient, established structure to data pri-
vacy. We believe this will make our data privacy management
more effective while optimizing efficiency.