Our guidelines for political engagement
The Siemens Managing Board holds overall responsibility for Siemens’ dialogue with political stakeholders, delegating company-wide coordination, and governance to the government affairs function. Within our businesses and countries, the respective business or country CEO is responsible for ensuring a coordinated dialogue with political stakeholders.
The government affairs function also manages and coordinates Siemens’ engagement with external lobbyists and memberships in selected intermediary organizations, such as industry and trade associations or think tanks. Political engagement and lobbying are generally conducted by Siemens employees, primarily within the government affairs department. In some countries, employees from related departments, like communications or legal, are additionally responsible for government affairs activities.
The Siemens Business Conduct Guidelines, dedicated Compliance Policies and the “Principles for Sponsoring Activities, Donations, Charitable Contributions and Memberships” govern our political engagement:
The Business Conduct Guidelines in particular safeguard Siemens’ zero tolerance approach to corruption, including in the political sphere, and demand that political activities are non-partisan as well as solely in support of Siemens legitimate business goals.
The Compliance Policies regulate the approval process for contracts with external suppliers, including for external lobbyists. They mandate the avoidance of conflicts of interest, including those arising from job rotations between the public and private sectors (“revolving doors ”). As reported in our audited Sustainability Statement (CSRD) for the last fiscal year: “No members of Siemens’ Managing or Supervisory Board appointed during the current reporting period held a comparable position in public administration within the two years prior to their appointment.”
The Compliance Policies also demand compliance with applicable national transparency requirements, such as registration in transparency registers.
With the links below, you can find Siemens’ most relevant lobbying registrations, which also display business associations we’re actively cooperating with at the respective regional, national or international level:
The “Principles for Sponsoring Activities, Donations, Charitable Contributions and Memberships” govern memberships in intermediary organizations, including approval processes. They explicitly prohibit to hold company memberships in political parties and any direct financial or in-kind contributions that “support partisan political purposes or the representation of partisan political interests (for example, election events for political campaigns)”.
As reported in our audited Sustainability Statement (CSRD) for the last fiscal year: “Direct political contributions are prohibited. Hence, Siemens monitors potential indirect contributions “made through intermediary organizations linked to or supporting particular political parties or causes”. This monitoring includes a review of all contracted external lobbyists as well as lobbying memberships in intermediary organizations where the annual membership fee exceeds the materiality threshold of five thousand euros. In the current reporting period, Siemens has made no direct or indirect financial or in-kind contributions to political parties, elected representatives or persons seeking political office.”
However, Siemens employees in the U.S. may make personal contributions to the Siemens Corporation Political Action Committee (SCPAC) as allowed by U.S. law. These are not Siemens Corporation contributions. Siemens may and does provide administrative support to the SCPAC, which includes the costs of operating the PAC, including supplies and other operating costs (such as legal and banking expenses) as governed by the applicable federal U.S. elections law. More information on applicable U.S. federal elections law can be found at www.fec.gov and www.fec.gov/rad/pacs/FederalElectionCommission-RAD-PACs.shtml
Political Engagement for employees as a mandate holder
Political Engagement is necessary for a functioning common good. For this reason, Siemens encourages and supports employees who want to help shape the social order and share responsibility for it by exercising a political mandate or taking on voluntary tasks outside of work. We see this as part of our social responsibility. Siemens has published an internal guideline to avoid conflicts of interest. If you have any questions, please contact our regional office in Munich government-affairs.de@siemens.com.
