Siemens 2013 Annual Report Download - page 225

253 D. Consolidated Financial Statements
357 E. Additional Information
245 C. Compensation Report, Corporate Governance
statement pursuant to Section a of the
German Commercial Code, Takeover-relevant
information and explanatory report
246 C. Siemens AG ( Discussion on basis of
German Commercial Code)
250 C. Notes and forward-looking statements

The Siemens Business Conduct Guidelines provide the ethical
and legal framework within which we conduct our business ac-
tivities. Our compliance system aims to ensure that all our world-
wide business practices remain within this framework as well as
in compliance with applicable laws. To serve this purpose, our
compliance system includes three pillars: prevent, detect and re-
spond. We are continuously working on further strengthening
compliance in the Company and to continue our efforts in com-
bating corruption, together with other market participants and
governmental organizations (Collective Action).
The Compliance Risk Assessment (CRA) process – in use as of
fiscal  – requires the CEOs and managers in the Company
to systematically determine and assess the compliance risks to
their units together with the responsible Compliance Officer
on an annual basis. These analyses have been performed for all
operating units of the Company in fiscal  and have been in-
corporated into the compliance risk analysis at group level
which aims to determine systematic and globally recurring com-
pliance
risks to the Company as promptly as possible. As well as
the CRA results, this analysis of the overall compliance risk at
group level takes into account, for example, the assessment of
compliance controls and results of case-related investigations.
Relevant risks are reported to the Siemens Enterprise Risk
Management (ERM) and measures to reduce the risks are
drawn up and implemented.
The Ask us help desk encourages our employees to ask their
compliance-related questions. Employees submitted  inqui-
ries 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 understanding
of compliance policies and processes among Siemens employ-
ees. Furthermore, all employees can pose questions directly 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. Furthermore, possible misbehavior may also be
reported directly, via the Managing Board or via supervisors to
the Compliance Organization, particularly to the Compliance
Officers in our individual company units. Our employees regu-
larly make use of this reporting channel. As a consequence, we
have decided to report the total number of compliance cases
requiring further inquiries or investigations reported through
all mentioned reporting channels from fiscal  (FY :
; previous fiscal: ).
On December , , Siemens launched a global US$ mil-
lion Siemens Integrity Initiative to support organizations and
projects that fight corruption and fraud through Collective
Action, education and training. This initiative is part of the
World Bank Siemens AG comprehensive settlement of July ,
. The status of the  projects funded within the first
funding round with a total contractual funding volume of
US$. million was presented to the World Bank in March
. On June , , Siemens started the second funding
round; it is intended to fund up to  projects with a total fund-
ing volume of up to US$. million.
On October , , the Company received the Year Four Re-
port from the Compliance Monitor Dr. Theo Waigel, whom
Siemens had engaged as part of the settlement reached with
the U.S. Securities and Exchange Commission (SEC) and the
U.S. Department of Justice (DOJ) in December . The Moni-
torship has ended after the full implementation of all Monitor
recommendations as was set forth in the settlement with the
U.S. authorities four years after the settlement date on Decem-
ber , .
We have a system of four compliance priorities to further de-
velop and improve our compliance system:
> Stand for Integrity: Our aim is to further encourage business
management responsibility for compliance and to continue
promoting responsible business practices in our markets
with Collective Action and the Siemens Integrity Initiative.
> Committed to Business: We want to leverage the Compliance
system to support sustainable growth and as a competitive
advantage.
> Manage Risk & Assurance: We continue to develop the com-
pliance risk management and to provide reliable assurance
for our business entities.
> Focus on Efficiency: We focus on increasing the efficiency of
compliance operations and collaboration.
These priorities have guided our activities in fiscal . These
included the compliance risk assessment covering all Siemens
operating units, the further implementation of the anti-trust
compliance program and measures to improve the efficiency
of compliance within the Company. Furthermore we have in-
troduced a new type of in-person compliance training focusing
on strengthening the responsibility and leadership by example
of our managers for Compliance.