Our compliance rules provide all our employees and managers with clear instructions for their business conduct. The processes and instruments we have developed integrate these requirements for good business conduct directly in the relevant business processes and thus support correct behavior.
The core of a successful compliance system is a reliable risk analysis in conjunction with the early detection of risks and the provision of appropriate measures. To this end, the company’s current assessment processes will be improved even further with the new Compliance Risk Assessment (CRA), which will be used starting in fiscal 2012. Not only does the CRA help reduce compliance risks through internal rules, tools, and controls, it also helps identify potential compliance risks, thus linking compliance even more closely to our business practices.
Internal compliance investigations are also an important source of information for the compliance risk analysis. Read more about this at “Detect”.
Absolutely clear, rigorously applied guidelines are an important lever in preventing violations of external and internal rules right from the start. As a central code of conduct, the Siemens Business Conduct Guidelines are the heart of our compliance system, yet it also contains numerous other rules that apply throughout the company.
Siemens requires of all its employees and managers that they always conduct themselves in accordance with all applicable laws and regulations and the company’s internal guidelines. The cornerstone of compliance for any company is the unequivocal directive by the senior management to all employees that all laws and regulations must be observed, accompanied by the equally clear warning that violations will not be tolerated. At Siemens, this directive is laid down in the Business Conduct Guidelines. Besides requiring all managers and employees to observe the law, these guidelines also stipulate precise rules to ensure compliance with competition laws and anti-corruption laws, the correct handling of donations, the avoidance of conflicts of interest in the exercise of job functions, compliance with the prohibition against insider trading, and the protection of company assets.
Our Business Conduct Guidelines are binding around the world for all employees and the members of the Managing Board. They must also be observed by the members of the Supervisory Board, where applicable. A completely revised and updated version of the Business Conduct Guidelines took effect in January 2009.
The Siemens Compliance System also encompasses numerous other company-wide rules that supplement the Business Conduct Guidelines. In order to increase the efficiency of our compliance system, we have simplified important compliance rules – without lowering their standards in any way – and integrated them more strongly in our business processes with the help of a variety of processes and instruments.
At Siemens, contributions in the form of sponsoring, donations, memberships and other gratuitous contributions are subject to uniform company-wide regulations. The purpose of these regulations is to maintain a clear separation of our business activities from our corporate citizenship, stakeholder engagement and marketing activities. Since fiscal 2010, all gratuitous contributions throughout the company must be processed using a uniform tool (SpoDoM).
You can find detailed information in the Chapter "Compliance guidelines".
Although invitations and gifts are customary and legitimate aspects of day-to-day business activities, they may not exceed certain limits. All our managers and employees are obligated to observe clear internal rules on this subject.
All contributions requiring approval must be approved using the above-mentioned SpoDoM tool. Before making any contributions to government officials or related persons, they must be checked against a scorecard to ensure compliance with the applicable rules and regulations.
You can find detailed information in the Chapter "Compliance guidelines".
Upholding high standards of compliance is especially important in the international project business. Siemens’ worldwide project business is subject to strict approval rules. In making the decision to proceed with a given project, the company systematically evaluates a wide range of legal, ethical, technical, economic, commercial and contractual criteria. To ensure compliance with the rules applicable to the project business, Siemens has implemented a uniform, worldwide tool to govern the project approval process.
You can find detailed information in the Chapter "Compliance guidelines".
Siemens mandates the company-wide use of a tool to evaluate the integrity of all potential business partners on the basis of risk considerations. The decision on whether to enter into a business relationship and what form it will take is made on the basis of the results of that review.
You can find detailed information in the Chapter "Compliance guidelines".
We impose a contractual obligation on our suppliers to abide by our Code of Conduct for Siemens Suppliers. In addition to basic requirements pertaining to human rights, labor standards, environmental protection and occupational safety, the Code also requires suppliers to comply with all relevant laws and regulations and refrain from corruption. We employ various monitoring instruments to verify suppliers’ compliance with our requirements.
You can find more information on our website under “Sustainability in the Supply Chain”.
Information on these and other internal rules is available under "Compliance guidelines".
Our employees and managers around the world receive regular training on the subject of compliance, as does top management. Beyond this, we particularly emphasize training for employees with certain functions, such as legal work, procurement or sales. Worldwide, new Compliance Officers must complete a four-day introductory course.
Now that we have successfully introduced a train-the-trainer concept for compliance training, our compliance organization and the in-house Siemens training facility carry out training measures without support from external experts.
All employees obligated to sign a declaration of commitment to our Business Conduct Guidelines must also complete web-based training on the subjects of combating corruption and anti-trust regulations. This training is intended to sharpen our employees’ awareness of compliance risks and provide them with basic knowledge of compliance regulations, which also include both important foreign laws and international agreements.
As part of web-based training on the Business Conduct Guidelines, we discuss compliance challenges using fictitious case studies. This web-based training deepens the participant’s understanding of the Guidelines and is meanwhile offered throughout the company in 16 different languages, including German, English and Chinese.
We have also integrated a compliance module in the introductory training for all new Siemens employees.
In order to ensure that our employees’ knowledge of compliance and correct business conduct remains current, our training programs include regular refresher courses for managers and employees with certain sensitive functions, such as sales.
Extensive communication measures help anchor compliance sustainably in the company. Employees and managers are informed of new measures and developments promptly via the intranet and e-mail, and our employee publications report regularly on compliance topics. We continually improve these measures as part of a compliance communication strategy that is oriented toward the long term.
The advice and support element relates to the compliance organization’s role and function of helping all Siemens business units implement compliance, thus contributing to our long-term business success. This element includes tools such as the “Ask us“ help desk, but it is primarily intended to foster close, confidential cooperation between the Compliance Officer and Siemens units.
The compliance help desk offers all Siemens employees around the world the opportunity to ask questions about the compliance system and about how its policies should be understood and practically applied. The help desk team ensures that these questions are answered accurately, with the help of additional experts where necessary. With this service, Siemens wants to help its employees clarify compliance-relevant questions in advance, but at the same time, the help desk is an important indicator of those compliance topics that are currently of particular importance to our employees.
In 2008, Siemens was one of the first companies in the world to make compliance part of its compensation system for top management. Another important aspect of compliance in personnel processes is the compliance screening we conduct of those employees who are destined for key company functions or for positions involving compliance, auditing or legal matters. Before a final decision is made, candidates for these positions are checked by the compliance organization to determine whether there are indicators of incorrect conduct (such as pending internal or governmental investigations) that could conflict with a promotion or appointment. All candidates are informed clearly in advance about this check by the Personnel and Compliance Discipline & Integrity departments, which are responsible for the process.
Going it alone has only a limited effect. If substantial progress is to be made, all market participants – or at least as many as possible – and other stakeholders must act in concert. That’s why Siemens has joined forces with other organizations to combat corruption through Collective Action. The Siemens Integrity Initiative supports organizations and projects that promote ethical markets and fair competition by combating fraud and corruption through collective action and through training and continuing education measures.
Extensive information on Collective Action and the Siemens Integrity Initiative