Siemens 2014 Annual Report Download - page 140

108 A. To our Shareholders 131 B. Corporate Governance
132 B. Corporate Governance Report
136 B. Corporate Governance statement pursuant to
Section a of the German Commercial Code
(part of the Combined Management Report)
138 B. Compliance Report
(part of the Combined Management Report)
144 B. Compensation Report
(part of the Combined Management Report)
165 B. Takeover-relevant information (pursuant to
Sections  para.  and  para.  of the
German Commercial Code) and explanatory report
(part of the Combined Management Report)

For us at Siemens, integrity means acting in accordance with
our values – responsible, excellent and innovative – wherever
we do business. A key element of integrity is compliance:
adherence to the law and to our own internal regulations. We
have zero tolerance for corruption and violations of the princi-
ples of fair competition – and where these do occur, we rigor-
ously respond.
The Compliance Report is an integral part of the Combined
Management Report.
Our Business Conduct Guidelines describe how we fulfill our
compliance-related responsibilities. They are also an expression
of our values and lay the foundation for our own internal regu-
lations. Our Business Conduct Guidelines are binding for all
employees worldwide.
Our Compliance System aims to ensure that all our worldwide
business practices are in line with these guidelines and in com-
pliance with all applicable laws. To serve this purpose and pro-
vide the Company with reliable protection against compliance
risks, our Compliance System has three pillars: Prevent, Detect
and Respond. We are continuously working to further strengthen
compliance in our Company and to combat corruption together
with other organizations (Collective Action).
We actively support the enactment of the United Nations Con-
vention against Corruption and the Anti-Bribery Convention of
the Organization for Economic Co-operation and Development
(OECD), which – like the ten principles of the United Nations
Global Compact – provide important guidance for our entire
organization. We are also actively involved in the Global Com-
pact. At the end of , our Chief Compliance Officer was
elected Chairman of the Task Force on Anti-Bribery / Corruption
of the Business and Industry Advisory Committee to the OECD.
Our activities in the World Economic Forum include the Com-
pany’s participation in the Pact Against Corruption Initiative
and the Siemens General Counsel’s membership in the Global
Agenda Council on Transparency & Anti- Corruption.
B.. Compliance priorities for fiscal 
Our compliance priorities provide the basis for the ongoing
development and further improvement of our Compliance
System. In this connection, we take into account and aim to
fulfill continuously evolving requirements in the compliance
field, which reflect both our own work and the changing mar-
ket conditions and compliance risks of our business activities.
For fiscal , we defined the following compliance priorities:
>
Stand for integrity: Our aim is to support business leadership
in its responsibility for compliance and to execute our Collec-
tive Action strategy focused on tangible business benefits.
> Committed to business: we want to foster trustful collabora-
tion between the Compliance Organization and our busi-
nesses as well as strengthen the market and customer focus
of compliance.
>
Manage risk & assurance: we want to continue to provide our
businesses with the appropriate level of assurance within
our Compliance System.
>
Responsibility for data privacy: we will assume new
responsibilities in the area of data privacy.
These priorities, which guided our activities in fiscal , in-
clude the conclusion of project- and market-specific Collective
Action agreements and the launch of the second funding
round of the Siemens Integrity Initiative. We have also carried
out a project to reinforce our business-partner compliance due
B. Compliance Report
Siemens Compliance System
Respond
> Consequences for misconduct
> Remediation
> Global case tracking
Detect
> Whistleblowing channels “Tell us”
and ombudsman
> Compliance controls
> Monitoring and compliance reviews
> Compliance audits
> Compliance investigations
Prevent
> Compliance risk management
> Policies and procedures
> Training and communication
> Advice and support
> Integration in personnel processes
> Collective action
Management responsibility