A strong commitment on the part of senior management, sometimes referred to as the “tone from the top,” is crucial for instilling a strong awareness of compliance issues throughout the company. Siemens also expects all its managers to act accordingly: Our senior managers are to serve as role models and must ensure that business decisions and actions in their areas of responsibility are always in complete accordance with the relevant legal requirements and our own values and guidelines.

In order to anchor compliance throughout the company over the long term, we have introduced a company-wide Compliance Review Process. At least every quarter, the senior management and the compliance organization at all organizational levels of the company discuss the status of the compliance program, its implementation, and major developments and cases. Reviews take place at shorter intervals of time in some organizational units. The Compliance Review Process aggregates the findings from the various reporting paths in the higher hierarchical levels of the company. The report of the Chief Compliance Officer to the Managing Board and the Compliance Committee of the Supervisory Board is based on the data and findings from the operational business, which were discussed with the managers there.