Implementation

Implementation of the Siemens Compliance Program

Chief Compliance Officer

Siemens has established a worldwide compliance organization headed by a Chief Compliance Officer. The Chief Compliance Officer reports to the Siemens Management Committee, the Corporate Executive Committee and the Audit Committee of the Supervisory Board of Siemens AG.

Regional Compliance Officers

In each of our more than 80 Regional Companies, Regional Compliance Officers have been appointed. Supported by additional compliance staff, these individuals are responsible for implementing the compliance programs in their own areas of responsibility and report to the Chief Compliance Officer.

In addition, they continually train employees regarding the requirements of the Compliance Program. They also ensure that every two years the entire management pledges in writing to abide by the Business Conduct Guidelines. The Compliance Officers are available as a first point of contact for reported infringements of the Business Conduct Guidelines and are responsible for investigating possible compliance violations. It is especially important to ensure that anyone reporting possible infractions is protected from reprisals. If a violation is confirmed, the Compliance Officers are responsible for executing disciplinary action.