Compliance and integrity go hand in handSiemens Energy 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 when conducting business. Our premise is this: Only clean business is Siemens Energy business. This applies worldwide and at all levels of the organization. In addition to combating corruption and competition and export-control violations, the Compliance Department also protects our company against fraud and money laundering as well as safeguards personal data and human rights.
What is the Siemens Energy compliance system?
The Siemens Energy 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 Energy 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 ombudsperson 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.
Code of Conduct for our business partnersSiemens Energy 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.
Selection and monitoring of our business partners
Under certain circumstances, Siemens Energy 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
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.
Channels for reporting misconductReliable 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 Energy, 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.
The Siemens Energy ombudsperson
In addition to "Tell us", Siemens Energy offers another channel for reporting compliance violations: the ombudsperson. The attorney Dr. Sibylle von Coelln from the law firm "HEUKING ∙ VON COELLN Rechtsanwälte", has been appointed the company’s external ombudsperson. Employees and third parties can confidentially and anonymously confide in this impartial professional should they observe improper business practices in the company.