In our continuous further development of the compliance system we consider the possibilities for improvement that we have identified and the changing requirements of our business. Ultimately, this development is best understood as a comprehensive, long-term change management process. Compliance remains top priority at Siemens.
Our employees’ assessments of our compliance provide important suggestions and information for the ongoing improvement of our system. The commitment of our employees is therefore an important force in the success of our compliance system as well as for our business success as a whole. Employee surveys are conducted every two years.
All the Business Units derive specific measures from the results of the survey, and the realization of these measures is tracked centrally and reported every quarter to the Managing Board as part of the compliance review.
Our employees can submit ideas and suggestions for improving the compliance system through the company-wide employee suggestion scheme.
The remediation process supports the Business Units in eliminating any deficiencies that have been identified. A group of specialists from the compliance organization tracks the implementation of the recommendations to ensure that deficiencies that have been identified are eliminated. Any structural failures in implementing the compliance system are identified and reported to internal auditors and to those responsible for the company’s compliance strategy so that important lessons from past cases can flow into the development of the compliance system.
In 2008, Dr. Theo Waigel was appointed as an independent Compliance Monitor at Siemens. The appointment of a monitor was a requirement of the Settlement Agreement reached between Siemens and the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) to settle the proceedings pending against Siemens.
This independent Monitor evaluated the effectiveness of the compliance system at Siemens and made regular reports to the DOJ and the SEC. As an independent agent, the Monitor delivered valuable suggestions for the ongoing improvement of the Siemens Compliance System.
Information on the Compliance Monitor’s Year Four Report is available in the Siemens Annual Report 2012 (Book II, page 118).
As was set forth in the aforementioned settlement, the Monitorship ended four years after the settlement date on December 15, 2012.
You will find more information on this in the corporate reports and under “Goals“.
2011-Feb-24 | Author