Compliance means leadership and responsibility 

To meet this challenge, we have restructured the Compliance Organization at Siemens and launched a comprehensive, global Compliance Program.

• By implementing the new Managing Board position for legal and compliance matters, headed since 1 October 2007 by Peter Solmssen, we have established compliance firmly as a key issue within the Siemens Managing Board. We have addressed the requirements for effective global integrity management at the organizational level by pooling the compliance issues and driving forward global standardization and personnel realignment in the areas of legal matters, compliance and audit. The new organizational structure is now fully established at the corporate level, and excellent progress is being made in the business units and regions. Our plan is to ensure that, from Fall 2008, over 400 compliance experts worldwide will be on hand as reliable consultants and multipliers to provide active support to business managers and drive forward the necessary change process.
  
• Compliance is first and foremost a leadership task, and leadership means taking responsibility. The Compliance Organization supports managers with effective processes, but does not absolve them of their leadership responsibility. To strengthen the compliance processes, we have established transparent, consistent organizational structures worldwide (chain of command) with clear responsibilities (CEO principle), while at the same time emphasizing the compliance responsibility of all employees in their individual roles.

This fiscal year, we have made compliance-related targets part of the incentive system for the senior management team worldwide. By incorporating compliance into the company's compensation system, we aim to strengthen and accelerate the change process.

Prevent – Detect – Respond: Three pillars of the Compliance Program 

• "Prevent": We are providing training, disseminating knowledge and implementing a control system to eliminate significant deficiencies. Training is exceptionally important because one of its aims is to ensure the correct implementation of the controls (e.g. in project management). To date, more than 15,000 employees have attended training events as part of the new anti-corruption program, and some 120,000 Siemens employees have completed the corresponding online training.
  
• "Detect": We rely on the sense of responsibility of Siemens employees, as well as their loyalty to the company, to help us identify problems at an early stage. Through our helpdesk with its "Ask us" and "Tell us" functions, we encourage our employees throughout the world to participate actively in building a culture of integrity and to show the red card to anybody who violates the rules. In just a few months, the "Ask us" helpdesk received around 3,000 questions regarding specific compliance issues, and many incidences of individual misconduct have been reported to "Tell us". This is evidence indeed of our employees' willingness and determination to uphold a corporate sense of responsibility and integrity.

In November 2007, we launched an amnesty program to support the uncompromising clarification of the corruption issues at Siemens. From its launch through to February 2008, this program received some 120 amnesty requests. In return for their cooperation, we have agreed not to assert any compensation claims against these employees and not to terminate their contract of employment. The external and internal investigations resulting from the many leads received are still ongoing.

• "Respond": Our response is to impose sanctions. We enforced around 500 disciplinary measures in fiscal year 2007, mostly for cases of fraud and corruption.

Open and honest communication is vitally important. This involves direct dialogue between the Managing Board/management team and the employees – in both directions. Another essential element is the effective provision of all necessary information via the intranet, compliance conferences and an easy-to-read Anti-corruption Compliance Guide.

Compliance affects the whole company

We are in the process of accounting for the past, while shaping the present and facing the challenges of the future. Compliance issues have changed our economy and society – and compliance has changed Siemens. We will show that we are moving in the right direction and that compliance is not an option but a principle that manifests itself right at the heart of the company, its employees and its business.

To this end, we will send clear signals: Misconduct will be sanctioned appropriately and consistently; nobody can hope to be saved by a "Siemens safety net" if they cross the red line.

We are engaged in a variety of cooperative projects with international organizations committed to fighting corruption and establishing and maintaining freedom of competition. 

For example, Siemens has a highly active role in the collective action workgroup of the World Bank Institute, and is a member of the United Nations Global Compact Working Group on the 10th Principle and the anti-corruption workgroup of the International Chamber of Commerce.

Through our cooperation with non-governmental organizations and international organizations, such as the World Bank, we are continuously working to improve our established Compliance Program in dialogue with our partners, exchanging knowledge with them to climb our shared learning curve more quickly.

Siemens wants to assume a leading role in compliance, integrity and transparency, with the clear objective of becoming a respected international partner in the fight against corruption.