§ 15a of the German Securities Trading Act (WpHG) requires members of the Managing Board and Supervisory Board of Siemens AG to report the purchase or sale of Siemens shares both to the company and to the German Federal Financial Supervisory Authority (BaFin). In addition to purchase and sales transactions involving Siemens shares, securities transactions relating to Siemens shares (e.g. purchase or sale of options or stock warrants for Siemens shares) must also be reported. The purchase, granting or exercise of options based on employment agreements or as a component of compensation are not subject to reporting requirements. Securities transactions by natural or legal persons closely related to any of the aforementioned persons are also subject to mandatory reporting.