Only clean business is Siemens business

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1 Only clean business is Siemens business Finn Baagøe Hansen Regional Compliance Officer/Country ECC Siemens A/S Page 1 Om Siemens Global virksomhed i mere end 190 lande Virksomheden Wind Power and Renewables Power and Gas Energy Management Building Technologies Elektrificering Power Generation Services Mobility Digital Factory Automatisering Process Financial Siemens Industries Services Healthcare and Drives Gmbh Digitalisering (forvaltes separat) Page 2 Handzettel 1

2 Siemens AG Nøgletal Nøgletal (I mio. ) FY 2015 FY 2014 Volumen Nye ordrer 82,340 77,657 Omsætning 75,636 71,227 Indkomst 1 7,380 5,507 Pengestrøm 1 4,674 5, september 30. september Medarbejdere Total Tyskland Uden for Tyskland Omsætning pr. division Healthcare 17 % Process Industries and Drives 13 % Digital Factory 13 % Mobility 10 % Omsætning pr. region Asien og Australien 20 % Power and Gas 17 % Wind Power and Renewables 7 % Energy Management 16 % Building Technologies 8 % Ikke inkluderet: Siemens Financial Services (SFS) Europa, CIS-lande, Afrika, Mellemøsten (excl. Tyskland) 36 % Amerika 29 % 1 Fortsættende og ophørte aktiviteter. Page 3 Tyskland 15 % Siemens AG Global tilstedeværelse - mere end 190 lande Tyskland 11,2 mia % 33 % Andel af den samlede total Europa (excl. Tyskland), CIS-lande, Afrika og Mellemøsten 27,6 mia % 28 % Andel af den samlede total Amerika 21,7 mia % Andel af den samlede total 21 % Asien og Australien 15,1 mia % Andel af den samlede total 18 % Omsætning ift. kunders lokationer Employees as of September 30, 2015 CIS: Fællesskabet af Uafhængige Stater Page 4 Handzettel 2

3 Regionalt hovedkontor Produktion Forskning og udvikling Salg og service Omsætning i FY 2015: DKK 24,8 milliarder Om Siemens Danmark Lokationer Investeringer siden 2003: > DKK 7 milliarder Ca ansatte Page 5 The Siemens Compliance System The Past Page 6 Handzettel 3

4 The disaster struck November 2006 headlines Possible scenarios Debarment from public tenders Penalties up to 10 billion Long-term damage to reputation and business Break-up of the company Page 7 Siemens Compliance Program : Focus on Prevent Detect Respond Prevent Detect Respond "Tone from the Top" Compliance Organization Training Policies & Procedures Program communication Centralization Continuous improvement Forensic & part of standard audits Compliance reviews Compliance controls Consequences for misconduct Global case tracking Monitoring effectiveness Compliance helpdesk (incl. Global Ombudsman function) Integration with personnel processes Source: Compliance Program Task Force Page 8 Handzettel 4

5 Compliance Control Framework 'Tone from the Top' 2 Compliance Organization Implementation of Policies and Procedures 5 3 rd Parties Tender & Contracts Gifts & Hospitality Finance & Accounting Training & Program Communication Case 9 Integration with Personnel Processes Tracking 10 Anti Trust Page 9 Policies, Procedures, Training and Communication In Person Web based Unrestricted Siemens AG All rights reserved. Page 10 Siemens Compliance Office Handzettel 5

6 Rapid reaction and implementation of our Compliance System, plus further development Immediate actions Implementation Support sustainable business Exchange of Leadership Team Tone from the top Independent investigation Centralization of bank accounts Settlement with authorities in Germany and in the U.S. Compliance program Compliance organization Compliance training Compliance tools Settlement with World Bank Continuous improvement Values & integrity Collective Action 2010 Active development of Compliance System/ external recognition XX First funding round Integrity Initiative Page 11 End of monitorship (Dec. 15, 2012) Dow Jones Sustainability Index: highest rating in the category Compliance for the fifth time in a row Second funding round Integrity Initiative Value based and mgmt. involvement The Siemens Compliance System Siemens Today Page 12 Handzettel 6

7 Putting values into practice That's what earns trust all over the world Responsible We undertake to conduct ourselves in an ethical and responsible manner Excellent Top quality, professional implementation, outstanding results Innovative A culture of continuous improvement step by step, day by day Page 13 Unrestricted Siemens AG All rights reserved. Tone from the top Striving for fair market conditions Only clean business is Siemens Business Zero tolerance The culture of a company and its values make the difference. People rightly associate Siemens with reliability, fairness and integrity. Joe Kaeser, President and CEO of Siemens AG Integritet Alt hvad vi gør, skal være etisk ansvarligt og overholde vores værdier. Det er, hvad integritet betyder for os. Vi måler os selv ved denne standard, og vi håber, at vores interessenter vil måle os med den samme standard. Siemens A/S 2013 Side 14 Corporate Communications Handzettel 7

8 The Siemens Compliance Organization Clear roles & responsibilities In addition, the compliance organization has overall responsibility for handling all compliance cases, in particular for investigating them and for taking punitive action when chargeable violations by Siemens employees are identified. These include, for example, violations of Criminal or administrative law and related internal regulations as well as criminal or administrative proceedings against the company or one of its employees. Unrestricted Siemens AG 2017 Page FBH/ RCO The Siemens Compliance System Management responsibility is the focus We constantly strive to further develop and improve the Compliance System Prevent Detect Respond Compliance risk management Policies and procedures Training and communication Advice and support Integration in personnel processes Collective Action Management responsibility Whistle blowing channels "Tell us" and Ombudsman Compliance controls Monitoring and Compliance reviews Compliance audits Compliance investigations Consequences for misconduct Remediation Global case tracking Unrestricted Siemens AG All rights reserved. Page Siemens Compliance Office Handzettel 8

9 If you are responsible for employees The defining element of the Siemens Compliance System is the responsibility of all Siemens managers for compliance. This management responsibility goes beyond the role-model function of senior management: As a manager of our company, you must exemplify compliance and ensure that business decisions and actions in their areas of responsibility are always in complete accordance with the relevant legal requirements and our own values and guidelines. As a manager, you bear particular responsibility for the success of this approach. To maintain high awareness for integrity and compliance topics at Siemens, an annual Integrity Dialog is conducted. The Integrity Dialog serves as a forum for managers to discuss recent compliance matters with their employees. raining.htm Unrestricted Siemens AG All rights reserved. Page 17 LC CB GF Our employees in dialog on Compliance with their line manager Integrity dialog in team meetings Objectives to maintain awareness of Compliance to provide a practical demonstration of management responsibility Managers discuss Compliance-related topics with their teams Contents: Risk-based selection of topics with central and local relevance Supported by Compliance Officer Repeated on annual basis Page 18 Handzettel 9

10 and continue with the constant development of the Compliance System Compliance has top priority Compliance priorities Compliance System to support sustainable growth and create a competitive advantage Risk-based further development of the Compliance System, in order to maintain high standards Stand for Integrity Committed to Business High rating and recognition of our Compliance System in the annual assessments for the Dow Jones Sustainability Index: top rating in the Compliance category for the 5th time in succession Managing Risk & Assurance Responsibility for Data Privacy Page 19 Business partner-related Compliance risks uniform risk-assessment of all relationships The Compliance Due Diligence process for Business Partners All business partners with an intermediary function between Siemens and the customer must undergo a risk assessment (uniform across the company and supported by a tool). Based on certain risk indicators such as, for example, the risk of corruption in the country of deployment a risk class (higher, medium or lower risk) is defined for the business relationship, which subsequently determines further procedure (Due Diligence, requirement for approval and mandatory contract clauses). Around 13,000 business partners are classified by using this process. Page 20 L Global Functions Handzettel 10

11 Compliance Risk in Project Sales and Project Execution Project Sales Compliance risks in the project sales phase are covered by the Limits of Authority (LoA)1) process. Project Execution Compliance risks in project execution Subcontractors Inappropriate payments to subcontractors Scrap/ excess/ surplus Material Scrap/ excess/ surplus material is misused for inappropriate purposes Customer decisions (e.g. change orders, acceptance, licenses permits) Inappropriate payments Identification and mitigation of Compliance risks In projects that indicate possible compliance risks, the Project Manager has to regularly identify and mitigate such risks in the project execution according to a specified Red Flag systematic and actively involves the respective Compliance Officer in the preparation of the acceptance of the project. 1 *: The LoA process is the internal approval procedure for external projects of Siemens. Unrestricted Siemens AG 2016 Page 21 Compliance in procurment Unrestricted Siemens AG 2016 Page 22 Handzettel 11

12 Different gifts & hospitality tools are available to cover the different risk areas Giving Accepting Meal/gift/local travel Entertainment lodging/non-local travel Any benefit from a 3 rd party Provision Scorecard Entertainment-SpoDoM Acceptance Scorecard Government al Private Government al & critical participants 1) Other participants Mandatory Voluntary Mandatory Voluntary Voluntary 1) Related Parties of Government Officials, healthcare providers, members of the purchasing department, invitees actively involved in the acceptance of a bid or the awarding of a tender Unrestricted Page 23 November 2016 Siemens Compliance Office Compliance Tools Business Partner Tool Registration, Risk Analysis, Due Diligence, Contract management SpoDoM Gift & Hospitality, Sponsoring, Donations, Memberships Registration, Pre-approval, Follow up LoA-Tool Anti Corruption Risk Assessment on Projects (Bid/No Bid) Unrestricted Siemens AG All rights reserved. Handzettel 12

13 Integrity requires taking responsibility and having the courage to make decisions following our inner compass Questions to guide Siemens employees towards compliant and responsible behavior Is it the right thing for Siemens? Is it consistent with Siemens core values and mine? Is it legal? Is it something I am willing to be held accountable for? If the answer is yes to all of those questions, don't worry, be confident Unrestricted Siemens AG All rights reserved. Page 25 Siemens Compliance Office The Siemens Compliance System Supporting sustainable business Page 26 Handzettel 13

14 Collective Action calls for high Compliance standards which benefit all market participants Fight corruption in concert with competitors and other players Create high compliance standards via a concept of prevention Customers Governments NGOs 1) Collective Action Integrate an independent institution for promotion and monitoring Society Define sanctions in case of violations Competitors 1) Non-Governmental Organizations such as Transparency International Page 27 Compliance indicators Compliance Indicators 1 Fiscal year Compliance cases reportes Disciplinary sanctions therein warnings therein dismissals Therein others Continuing and discontinued operations. 2 Includes loss of variable and voluntary compensation elements, transfer and suspension. Source: Siemens Sustainability Information 2015 Unrestricted Siemens AG 2016 Page 29 XX.XX.20XX Author / Department Handzettel 14

15 Thank you for your attention? Finn Baagøe Hansen Regional Compliance Officer Country ECC Borupvang Ballerup Phone: Mobile: finn.baagoee@siemens.com siemens.com/compliance Page 30 Handzettel 15

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