Measures
Improvement of Siemens’ compliance system: measures to ensure full compliance within the company
In the wake of the accusations leveled at individual company employees at the end of 2006 (suspicion of breach of trust, bribery and tax evasion), Siemens initiated comprehensive measures to ensure full compliance within the company:
- Attorney Hans-Otto Jordan of the Nuremberg law firm Dr. Beckstein & Partners has been retained to act as an external ombudsman and provide a protected communication channel. Employees and third parties can contact this neutral individual on a confidential and anonymous basis if they have noticed any incorrect business practices in the company.
Ombudsman
Monitoring of the Compliance Program - A leading law firm, Debevoise & Plimpton LLP, was retained to conduct an independent investigation of possible compliance violations at Siemens as well as of the company’s compliance and control systems.
- Michael J. Hershman, an internationally recognized anti-corruption expert and co-founder of Transparency International, was appointed compliance advisor and assigned to examine Siemens’ compliance rules and systems. Specifically, he will advise the Audit Committee and the Managing Board on the setup of the company’s compliance organization, the conduct of compliance reviews, and the review and, where necessary, the adoption of anti-corruption rules and guidelines. He will also help develop required communications and training measures.
- The Compliance Office has been directly assigned to the company’s legal department to facilitate close cooperation with the financial audit department and to ensure direct access to the resources needed to investigate the current situation.
- Siemens has newly issued, replaced or revised a number of regulations that supplement the Business Conduct Guidelines worldwide. more
