Siemens 2014 Annual Report Download - page 142

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)

B.. Compliance training
One focus of our preventive measures under the Compliance
System is to provide compliance training to all managers and
employees who hold positions with a particular risk profile. In
fiscal , the definition of these “sensitive functions” was ex-
panded and specified more precisely. In accordance with this
definition, the Compliance Officers of the relevant Company
units identify the managers and employees whose participa-
tion is required and ensure that they attend the training
sessions. They monitor and confirm the fulfillment of these
require ments at regular intervals.
Our Company-wide compliance training portfolio consists of
in-person and web-based training programs. The in-person
training programs also provide our employees with an opportu-
nity to discuss correct behavior based on day-to-day work
examples. In fiscal , we introduced an annual Integrity
Dialog to maintain a high awareness of integrity and compli-
ance topics at Siemens. The Dialog, which is conducted across
the entire Company, serves as a forum for managers to discuss
recent compliance matters with their employees.
The assessment and analysis of compliance risks for the oper-
ating units and at Group level offers important indicators that
help us develop and define the focus of our training activities,
including the selection of themed modules for the annual
events held in conjunction with the Integrity Dialog. Our oper-
ating units address specific challenges by enhancing their
training activities with additional topics from their own busi-
nesses or by extending the mandatory target groups for spe-
cific compliance training programs in their units. In this way,
our training activities reflect both Siemens-wide topics and the
key topics specific to the operating units.
B.. Compliance indicators
Compliance indicators
Year ended September, 
 
Compliance cases reported 653 908
Disciplinary sanctions 195 305
therein warnings 114 188
therein dismissals 50 75
Therein other  31 42
1 Continuing and discontinued operations.
2 Includes loss of variable and voluntary compensation elements, transfer and
suspension.
The “Tell us” help desk and the Company’s ombudsman are two
secure reporting channels that can be used by our employees
and external stakeholders to report violations of external and
internal rules. Reports to these channels are passed on to our
Compliance Organization. Possible misconduct may also be
reported directly via the Managing Board or via supervisors
to the Compliance Organization and, in particular, to the
Compliance Officers in our individual company units. Our
employees regularly make use of this reporting channel. In fis-
cal , the total number of compliance cases requiring
further inquiries or investigations reported via all the above-
mentioned reporting channels was . We believe that the
decrease from fiscal  () is within the normal range of
variation.
The total number of disciplinary sanctions for compliance vio-
lations in fiscal  was  (fiscal : ). The disciplinary
sanctions reported in a specific fiscal year do not all relate to
the compliance cases reported in the same period: disciplinary
sanctions are frequently not implemented in the year in which
a case was reported. This is due to the fact that a reported com-
pliance case has to undergo the Company’s entire internal case
handling process (see top right), from the mandating and per-
forming of an internal investigation to the documentation of its
results in an investigation report that will form the basis for
related disciplinary sanctions and remediation measures.
Furthermore, a single reported compliance case may, for
instance, result in several disciplinary sanctions or in no disci-
plinary sanctions at all – for instance, because the employee
concerned meanwhile has left the company for some other
reason. Therefore, too, it is not possible to establish a direct
correlation between the numbers of reported compliance cases
and the numbers and types of disciplinary sanctions
implemented in a given reporting period.
In our view, the detected compliance violations in our Company
in the past fiscal year demonstrate once again that our
Compliance System was properly designed and is being imple-
mented effectively.
The “Ask us” help desk encourages our employees to ask com-
pliance-related questions. Incoming questions are automati-
cally forwarded without prior registration to the Compliance
Officers responsible for the employees’ entities. Furthermore,
all employees can pose questions directly to the Compliance
Officers responsible for their respective units. Most employee
questions are now being handled and answered in this way.
These questions are not registered either. In light of these
develop ments, we have decided to discontinue the reporting
of inquiries submitted to the “Ask us” help desk.