Siemens 2014 Annual Report Download - page 143

171 C. Combined Management Report 247 D. Consolidated Financial Statements 337 E. Additional Information
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B.. Data privacy
In line with our compliance priorities for fiscal , we’ve con-
tinued to integrate data privacy into our Company’s Compliance
System. Selected measures include the integration of data
privacy into the Compliance Risk Assessments, data privacy
reporting via our quarterly Compliance Performance Review
and the inclusion of data privacy incidents in our global compli-
ance case tracking tool.
Data protection laws in the European Economic Area (EEA)
require a recipient of personal data located outside the EEA to
provide a level of data protection equivalent to the level of data
protection in the EEA. As a result, the instrument of Binding
Corporate Rules (BCR) was developed at European Union level
to allow multinational groups of companies, such as Siemens,
to make transfers of personal data across borders and between
group companies that implement the BCR in compliance with
the aforementioned requirement. In this context, Siemens
has issued, effective fiscal , its BCR for the Protection of
Personal Data within the Company.
B.. Company-wide award
for integrity and compliance
In , we made compliance excellence a component of the
incentive system for our senior management. This system was
not designed to honor basic compliance with the law and inter-
nal regulations, which is always expected. Instead, it focused
on rewarding managers for “going the extra mile” in imple-
menting our Compliance Program and driving a culture of
integrity. This approach proved useful in the following period.
It was subsequently replaced by a specific process for dealing
with weak compliance performance on the part of managers.
As part of this process, a corrective factor is applied to bonus
payments if remedial action is not taken following the issuance
of a ”yellow card.”
Effective fiscal , the consideration of weak compliance per-
formance on the part of managers has been made a mandatory
element of the Company’s bonus regulations. In addition, re-
lated performance issues will also be addressed through the
Compliance Organization. In light of the above and to reinforce
the recognition of exemplary commitment to integrity and
compliance within the Company, an annual award for integrity
and compliance will be presented starting in fiscal . The
award will honor outstanding examples of management
responsibility for compliance and employee commitment to
compliance. In addition to recognition by Company manage-
ment, the competition will promote best practices within
Siemens and encourage others to follow these examples.
B.. Collective Action
and Siemens Integrity Initiative
If substantial progress is to be made in combating corruption
and fostering fair competition, as many stakeholders as pos-
sible must act collectively. That’s why we have joined forces
with other organizations to fight corruption and promote
ethical markets through collective action and the Siemens
Integrity Initiative.
Compliance investigation process
Allegation
received
Assessment
carried out
by examining
or evaluating
the allegation
before
mandating an
investigation
Mandating Research and
planning
Investigation Preparation
of the investi-
gation report
Disciplinary
measures and
remediation
Compliance case
Compliance investigation