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Compliance is a top management priority for Siemens. That’s why the global Legal and Compliance Department falls directly under the purview of CEO Joe Kaeser.
Siemens shows zero tolerance toward corruption, violations of the principles of fair competition and other breaches of the law – and where these do occur, we take swift action. But compliance means much more than just adhering to laws and to the regulations described in the Siemens Business Conduct Guidelines. Compliance forms the basis for all our decisions and activities, and it is the key to integrity in conducting business. Our premise is this: Only clean business is Siemens business. This applies worldwide and at all levels of the organization.
In addition to combating corruption and competition violations, the Compliance Department also protects our company against fraud and money laundering as well as safeguards personal data.
We are also active in international organizations that strengthen responsible business practices. Since late 2013, our Chief Compliance Officer has chaired the Anti-Bribery and Corruption Policy Group of the Business and Industry Advisory Committee to the OECD.
The Siemens compliance system comprises a comprehensive system of measures to ensure our business is always carried out in full accordance with the law as well as with our internal principles and rules. In the process, we also want to instill the notion of responsible conduct in everything that Siemens employees think and do.
Our Compliance System is divided into three levels of action: prevent, detect and respond. Preventative measures include, for example, compliance risk management, guidelines and procedures, and comprehensive training and advising of employees. Communication channels such as our “Tell us” reporting system and ombudsman as well as fair internal investigations are indispensable to recognizing and resolving matters of misconduct. Unambiguous responses and clear consequences serve to punish misconduct and eliminate weaknesses. The responsibility all managers carry for compliance is the overarching element above these three levels.
Our company’s active ownership culture makes the difference. Above and beyond ingenuity, people rightly associate Siemens with reliability, fairness and integrity.
Zero tolerance for misconduct
Siemens has required its suppliers and business partners with an intermediary function to adhere to a code of conduct. This code is modeled after the 10 principles of the United Nations Global Compact. It covers legal compliance in general and our anticorruption policies in particular, including provisions against anticompetitive practices and conflicts of interest.
Using audits, we systematically identify potential risks in our supply chain and collaborate with our business partners and to ensure they comply with the Siemens Code of Conduct.
Under certain circumstances, Siemens can be held legally responsible for the actions of its business partners. We counter this risk by taking a comprehensive approach to selecting our partners, by contractually obliging them to adhere to our Code of Conduct, and by monitoring the ongoing collaborations. This process covers the entire life cycle of the business partnership. Our compulsory companywide Business Partner Compliance Tool supports implementation of the process and ensures documentation of relevant information and activities. And we systematically harness the potential of big data using dashboards and analytics to improve risk management and the monitoring of our business-partner relationships.
Integrating compliance into our business processes has played a crucial role in creating an effective compliance system, and a key aspect of this has been educating our customers about our compliance principles.
One example of this took place in 2017 at the Hannover Messe, the world’s most important industry trade fair. There the Digital Factory and Process Industries and Drives divisions presented the game “Compliance included …” to their customers. When it comes to compliance, this is what Siemens is all about: clean business, always and everywhere!
“Tell Us” and Siemens ombudsman
Reliable reporting channels for internal and external stakeholders and the protection of internal whistle-blowers from sanctions help ensure possible misconduct is reported, thoroughly investigated and clarified. At Siemens, we provide different reporting channels to internal and external whistle-blowers to inform us about possible compliance violations.
The “Tell us” compliance reporting system provides a secure channel for reporting this information 24 hours a day: online or by telephone, anonymously if desired, and in several languages.
In the 2017 fiscal year, 667 alleged compliance infringements prompted further inquiry or investigation. That same year, disciplinary measures for compliance violations totaled 217. A special directive protects Siemens employees who report misconduct in good faith and to the best of their knowledge from company retribution.
In addition to "Tell us", Siemens offers another channel for reporting compliance violations: the ombudsman. Andreas von Máriássy, from the Munich-based law firm von Máriássy Dr. von Stetten, has been appointed the company’s external ombudsman. Employees and third parties can confidentially and anonymously confide in this impartial professional should they observe improper business practices in the company.
The Siemens Integrity Initiative supports organizations and projects that combat corruption and fraud through Collective Action as well as education and training in order to promote clean markets and fair competition. As part of comprehensive settlements between the World Bank Group and Siemens AG in July 2009 and between the European Investment Bank and Siemens AG in March 2013, the Siemens Integrity Initiative supports projects that have a clear focus on business and can demonstrate objective and measurable results with the potential for expansion and replication in the future.
Siemens has committed to funding organizations and projects that combat corruption and fraud through Collective Action initiatives as well as education and training in three funding tranches over 15 years. For the first two Funding Rounds, 55 projects with more than US$ 70 million in funding and project durations of 3 to 5 years were carefully selected from an international pool of applicants. Among those selected was the newly founded International Anti-Corruption Academy based in Vienna, which provides a new and holistic approach to anti-corruption education and research and delivers training and technical support to a wide variety of stakeholders.