Government Affairs at Siemens

“Continuous dialog with political decision-makers is highly relevant for the success of a global company. We are committed to political neutrality. Siemens activities with respect to politicians, parties, and positions will be non-partisan, and solely in support of Siemens business goals. We comply with the law and Siemens guidelines.”
- Siemens Business Conduct Guidelines (SBCG), Chapter G.1. Fair competition: we place integrity at the heart of everything we do.

Guiding principles

Siemens operates in nearly every country in the world, has customers in the private and public sectors, and covers a wide range of industries.
As a result, the way policy, regulations and legislation are shaped has a direct impact on Siemens. Therefore, maintaining a dialogue with political decision-makers is crucial for our company’s success and for our commitment to corporate citizenship.

Siemens defines political activities as any communication, policy advocacy or lobbying towards political leaders, policy-making institutions and authorities (collectively “policymakers”). These activities are conducted either directly, by Siemens employees - or indirectly, through our memberships in associations and through our use of external agencies. All activities are aligned with company goals and positions and are carried out in a coordinated and consistent way, as per the policies and guidelines below.

Governance and accountability

“We are open and honest. We take our responsibility seriously, we are reliable, and we only make promises we can keep.”
- SBCG, Chapter C. We create trust.

The overall responsibility for Siemens’ dialog with policymakers lies with our Managing Board, which has given the Government Affairs (GA) department a mandate for company-wide coordination tasks and the corresponding governance responsibilities. The GA Department is part of the “CEO Office” which reports directly to the President and CEO of Siemens, Dr. Roland Busch.

The GA Department is responsible for developing political and advocacy strategies to advance Siemens’ interests and to advise and support management regarding any interaction with policymakers. In addition, the GA Department manages and coordinates Siemens’ participation in relevant industry associations and membership organizations. All strategies and activities are closely aligned or even created with the respective Siemens’ business units and local units at our Regional Companies.

Siemens takes an integrated approach to managing our political activities in accordance with our company-wide compliance principles and procedures. Our employees must obey the laws and regulations of the legal systems within which they are operating. Compliance is firmly embedded throughout our company, primarily through our mandatory Siemens' Business Conduct Guidelines (SBCG). These guidelines contain the basic principles and rules governing the way we act within our company as well as in relation to our partners and the general public. Further details can be found on our compliance website, in our DEGREE framework for sustainability and in our most recent Sustainability Report.

“Revolving Door” guidelines

Siemens has adopted internal guidelines for handling the so-called “Revolving Door” practices, in particular to avoid conflicts of interest. These guidelines apply when people move between the private and public sectors. Among other things, these guidelines specify the following principles:

• Examine and comply with relevant legal requirements
• To avoid any conflicts of interest, thoroughly check and compare the subject matter and working environment of the previous activities with the planned position; involve the GA Department as well as the Legal and Compliance Department in any decision
• Document the selection process and make it transparent
• In all cases, also observe the Siemens Business Conduct Guidelines

As part of this approach, Siemens adheres to “cooling off” periods as required by local regulations.

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 regionaloffice.munich.de@siemens.com

No tolerance with non-compliant behaviour

“We do not tolerate any form of corruption in our business dealings anywhere in the world. This includes our business dealings through our external partners.”
- SBCG, Chapter G.1. Fair competition: we place integrity ate the heart of everything we do

At Siemens, we take a zero-tolerance approach to corruption, violations of fair competition principles, and breaches of applicable law and of our own internal regulations, including our government affairs policies. This zero-tolerance approach applies to our employees, our suppliers and our business partners. If events of this nature do occur, we respond vigorously –worldwide and at all levels of the organization. For Siemens, integrity means acting in accordance with our values – responsible, excellent, and innovative – wherever we do business.

Siemens offers several channels for reporting compliance concerns to internal and external parties. More details can be found here. The handling of compliance cases at Siemens follows a clearly structured approach that encompasses all steps in the process, ranging from keeping reporting channels open to performing internal investigations of possible compliance violations and to implementing our responses to compliance-related incidents.

Transparency Registers

Siemens answers the increasing demand for openness and accountability in political interactions, in particular by entering official “Transparency Registers” on regional and national levels. You can view our most recent entries via these links:

• EU Transparency Register
• U.S. Lobbying Disclosure Act Registration
• Lobbying Register for the Representation of Special Interests vis-à vis the German Bundestag and the Federal Government (in German language only)
• Bavarian Lobbyregister (in German language only)

Political Contributions:

“Bribery is the act of offering, promising, or giving money, gifts, or other benefit to a public official or public or private employee with the aim of receiving improper advantages. Bribery is a criminal offense worldwide.”
- SBCG, Chapter G.1. Fair competition: we place integrity at the heart of everything we do

Siemens does not make any direct financial or in-kind “political contributions” to political parties, their elected representatives or persons seeking political office – for example in order to support election campaigns. Our strong internal Siemens Business Conduct Guidelines (SBCG) prohibit such givings. In addition, these guidelines demand Siemens to be politically neutral.

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.

“Sponsorships, donations, charitable contributions, and memberships […] must be religiously and politically neutral […]”
- SBCG, Chapter G.1. Fair competition: we place integrity ate the heart of everything we do

All sponsorships, donations, gifts and hospitality, as well as memberships and the engagement of external business partners, agencies and lobbyists throughout the company, are subject to a mandatory approval process that involves the Compliance Department. Our internal rules furthermore clearly state that sponsorships as well as donations may not be politically or religiously motivated. Also, invitations of public officials to entertainment events require the approval of a compliance officer.

The above-mentioned regulations are taken from our internal policy, “Principles for Sponsoring Activities, Donations, Charitable Contributions and Memberships.”

“We maintain business relationships only with reputable partners who comply with the law.”

- Siemens Business Conduct Guidelines (SBCG), Chapter J. Our partners: we work with responsible partners

I) External agencies and lobbyists

Although Siemens employees carry out the majority of our Government Affairs activities, we do engage the services of some external agencies to assist us. Siemens employees must adhere to an internal policy which is defining strict rules for engaging such agencies and external lobbyists. We use comprehensive procedures to select them, as we do with all our external business partners. The selection of external lobbyists is subject to our business partner process and requires approval from the Government Affairs Department as well as the Compliance Department. These relationships are continuously monitored and audited.

All our suppliers and third-party intermediaries are contractually obliged to adhere to our Siemens Code of Conduct for Suppliers and Third-Party Intermediaries, and compliance is monitored on an ongoing basis. Additionally, we apply special contract clauses for some business partner categories, such as external lobbyists. This process covers the entire lifecycle of the business partnership. Our compulsory company-wide Business Partner Compliance Tool supports implementation of the process and ensures documentation of relevant information and activities. More details can be found here.

II) Membership organizations

Siemens and its consolidated subsidiaries participate in a wide range of trade associations and membership organizations, some of which engage in lobbying activities on behalf of their members. All such memberships are subject to mandatory approval processes to ensure compliance with Siemens’ Business Conduct Guidelines - above all, to prevent any violation of the prohibition against corruption and the principles of fair competition. The section below lists our most important memberships in our three main markets.

Europe:
Bundesverband Informationswirtschaft, Telekommunikation und neue Medien e.V. (BITKOM); BUSINESSEUROPE (only ASG); DIGITALEUROPE; European Roundtable of Industrialists (ERT); European Policy Center (EPC); Asia-Pacific Committee of German Business (APA) at the Federation of German Industries (BDI); International Business Congress (IBC); German Mechanical Engineering Industry Association (VDMA); German Electrical and Electronic Manufacturers’ Association (ZVEI)

USA:
U.S. Chamber of Commerce; National Electrical Manufacturers Association; National Foreign Trade Council (NFTC); Global Business Alliance (GBA); Alliance to Save Energy

China:
European Union Chamber of Commerce in China (EUCCC); the German Chamber of Commerce in China (AHK Greater China)