Handling of Complaints
Process for handling complaints related to accounting practices
To uncover infractions in accounting and auditing, Siemens has established a special process for handling complaints related to accounting practices. This process is based on the requirements of the Sarbanes-Oxley Act. Under Section 301 of the Sarbanes-Oxley Act, a company’s Audit Committee must establish a process that enables employees and third parties to submit accounting related complaints anonymously if they so choose, and to ensure that such complaints are correctly processed. According to the current rules of procedure, which are published company-wide, all accounting-related complaints are submitted to the Chief Compliance Officer, who initiates an investigation by the company’s financial auditors and reports to Siemens’ Audit Committee.
Complaints and Comments according to paragraph G of Siemens’ Business Conduct Guidelines
Any employee may lodge a personal complaint with his/her supervisor, the Personnel Manager, or some other person/unit designated for this purpose or with an existing internal works council, or indicate circumstances which point to a violation of the Business Conduct Guidelines. The matter will be investigated thoroughly. The corresponding measures will be implemented if appropriate. All documentation will be kept confidential. No reprisal of any kind will be tolerated. Employees should exhaust the internal possibilities of mediation.
Ombudsman: Handling of complaints regarding irregular business practices
Since December 7, 2006, employees and third parties may contact the Ombudsman anonymously and in confidence if they have become aware of any irregular business practices in the company. Siemens has entrusted Hans-Otto Jordan – a lawyer practicing in Nuremberg.
If, following a plausibility check, there is any suspicion that violations of the criminal law or the Business Conduct Guidelines have occurred, the Ombudsman will forward this information to the Corporate Compliance Office. In so doing, the Ombudsman will, due to the confidentiality ensured under attorney-client privilege, guarantee the anonymity – also vis-à-vis the company – of the individual providing the information. The Corporate Compliance Office will initiate an investigation of the facts provided by the Ombudsman. All units in the company must support the Corporate Compliance Office in the performance of its tasks. The Corporate Compliance Office will report to the Ombudsman and to the Chief Compliance Officer (CCO) on the progress and results of investigations.
With the introduction of the HelpDesk Siemens offers employees and third-parties a worldwide, round-the-clock outlet for complaints relating to violations of the Business Conduct Guidelines.