Business Conduct Guidelines 2008-V1-de2 - Siemens · · 2013-10-01Business Conduct Guidelines,...

Corporate Compliance Office

Siemens Business Conduct GuidelinesJanuary 2009

2 Business Conduct Guidelines, Edition 2009-01

Business Conduct Guidelines 2009

3Business Conduct Guidelines, Edition 2009-01

Foreword

In the more than 160 years of its existence,our Company has built an excellent reputa-tion around the world. Technical perfor-mance, innovation, quality, reliability, andinternational engagement have madeSiemens one of the leading companies inelectronics and electrical engineering. It istop performance with the highest ethicsthat has made Siemens strong. This is whatthe Company should continue to stand forin the future.

These Business Conduct Guidelines pro-vide the ethical and legal framework withinwhich we want to maintain successful ac-tivities. They contain the basic principlesand rules for our conduct within our Com-pany and in relation to our external part-ners and the general public.

They set out how we meet our ethical andlegal responsibility as a company and giveexpression to our corporate values of being“responsible – excellent – innovative.”

These Business Conduct Guidelines havebeen adapted in line with new legal re-quirements and are based on internationaltreaties on human rights, anti-corruptionand sustainability. They are intended tostrengthen awareness of the law and moralstandards as an integral part of our entre-preneurial actions. The key message is thatonly clean business is Siemens business.

I call on all employees to live and breathethe Business Conduct Guidelines.

Peter LoescherPresident and CEO

January 2009


Business Conduct Guidelines 2009


Content

Foreword . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

A. Basic Behavioral Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

A.1. Behavior which Complies with Law . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6A.2. Mutual Respect, Honesty and Integrity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6A.3. Responsibility for the Reputation of Siemens . . . . . . . . . . . . . . . . . . . . . . . . . 7A.4. Management, Responsibility and Supervision . . . . . . . . . . . . . . . . . . . . . . . . . 7

B. Treatment of Business Partners and Third Parties . . . . . . . . . . . . . . . . . . . . . . . 8

B.1. Fair Competition and Anti-Trust Laws . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8B.2. Anti-Corruption: Offering and Granting Advantages . . . . . . . . . . . . . . . . . . . . 9B.3. Anti-Corruption: Demanding and Accepting Advantages . . . . . . . . . . . . . . . . 10B.4. Political Contributions, Charitable Donations and Sponsoring . . . . . . . . . . . . 10B.5. Government Procurement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11B.6. Anti-money Laundering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11B.7. Trade Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12B.8. Working with Suppliers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

C. Avoiding Conflicts of Interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

C.1. Competing with Siemens . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14C.2. Sideline Work . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14C.3. Interests in Third Companies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

D. Handling of Company Property . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

E. Handling of Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

E.1. Records and Financial Integrity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18E.2. Confidentiality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18E.3. Data Protection and Data Security . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19E.4. Insider Trading Rules . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

F. Environment, Safety and Health . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

F.1. Environment and Technical Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22F.2. Work Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

G. Complaints and Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

H. Compliance Implementation and Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . 25

Further Information and Contacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

Appendix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28


A. Basic BehavioralRequirements

A.1. Behavior whichComplies with LawObserving the law and the legal systemin every country where we do business is a fundamental principle for Siemens1.All employees must obey the laws andregulations of the legal systems withinwhich they are operating in addition toapplicable Siemens policies. Violationsof the law must be avoided under allcircumstances.

Regardless of the sanctions that could beimposed by law, all employees guilty of aviolation will be subject to disciplinaryconsequences because of the violation oftheir employment duties.

A.2. Mutual Respect,Honesty and Integrity We respect the personal dignity, privacy,and personal rights of every individual.We work together with individuals ofvarious ethnic backgrounds, cultures,religions, ages, disabilities, races, sexualidentity, world view and gender. Consis-tent with our corporate principles andwith the employment laws of numerouscountries in which we work, we do nottolerate discrimination against anyone onthe basis of any of these characteristicsor harassment or offensive behavior,whether sexual or otherwise personal.

These principles apply to both internalcooperation and conduct towards exter-nal partners. We make decisions aboutthose we work with – including person-nel, suppliers, customers and businesspartners – based only on appropriateconsiderations, not on the basis of inap-propriate considerations such as discrimi-nation or coercion.

We are open, honest and stand by ourresponsibilities. We are reliable partnersand make no promises we cannot keep.And we expect our employees to actwith integrity.

1 References to “Company“ or “Siemens“ are toSiemens AG and its subsidiaries.


A.3. Responsibility for theReputation of SiemensTo a substantial degree, the reputationof Siemens is determined by our actionsand by the way each and every one of uspresents and conducts himself/herself.Illegal or inappropriate behavior on thepart of even a single employee can causethe Company considerable damage.

Every employee should be concernedwith maintaining and promoting thegood reputation of Siemens in the re-spective country.

A.4. Management, Respon-sibility and SupervisionThe culture of integrity and compliancein an organization starts at the top. Allmanagers must fulfill their duties of or-ganization and supervision. All managersbear responsibility for all employees en-trusted to them. All managers must earnrespect by exemplary personal behavior,performance, openness, and social com-petence. This means, among otherthings, that each manager must empha-size the importance of ethical conductand compliance, make them regular top-ics of everyday business and promotethem through personal leadership andtraining. Each manager must also setclear, ambitious and realistic goals andlead by example.

Managers should permit their employeesas much individual responsibility and lee-way as possible, while making it clearthat compliance is required under all cir-cumstances, at all times. All managersshall also be accessible in case employeeswish to raise compliance concerns, askquestions or discuss a professional orpersonal problem.

These responsibilities of managers do notrelieve employees of their own responsi-bilities. We must all work together tocomply with applicable laws and Siemenspolicies. These specific manager respon-sibilities are listed here to give employeesan idea of the leadership and supportthey should expect from their superiors.

It is the responsibility of all managers tosee to it that there are no violations oflaws within their area of responsibility

that proper supervision could have pre-vented. They still remain responsible,even if they delegate particular tasks.

In particular, the following duties applyto managers:

1. The manager must carefully selectemployees based on their personaland professional qualifications andsuitability. The duty of due care in-creases with the significance of thetask the employee must perform(duty of selection).

2. The manager must give precise,complete and binding instructionsto employees, especially with re-gard to compliance with the law(duty to give instructions).

3. The manager must ensure thatcompliance with the law is con-tinuously monitored (duty of monitoring).

4. The manager must clearly commu-nicate to employees the impor-tance of integrity and compliancein everyday business. He/she mustalso communicate that violationsof the law are unacceptable andwill have employment conse-quences (duty of communication).


B. Treatment of BusinessPartners and Third Parties

B.1. Fair Competition andAnti-Trust LawsFair competition permits markets to de-velop freely – with attendant social bene-fits. Accordingly, the principle of fairnessalso applies to competition for marketshare.

Every employee is obliged to abide by therules of fair competition.

Anti-trust evaluation can be difficult, par-ticularly because the rules can differ fromcountry to country and from case tocase. For example, in many places specialanti-trust law requirements apply to largecompanies.

Here are examples of the types of behav-ior that can lead to a violation of anti-trust laws. Employees may not:

• talk to competitors about prices,output, capacities, sales, bids, prof-its, profit margins, costs, methodsof distribution or any other parame-ter that determines or influencesthe Company’s competitive behaviorwith the aim to solicit parallel be-havior from the competitor,

• enter into an agreement with acompetitor not to compete, to re-strict dealings with suppliers, tosubmit bogus offers for bidding orto divide up customers, markets,territories or production programs,

• have any influence on the resaleprices charged by our purchasers, orattempt to make them restrict theexport or import of goods suppliedby Siemens.

Moreover, employees may not obtaincompetitive intelligence by using indus-trial espionage, bribery, theft or electro-nic eavesdropping, or communicateknowingly false information about acompetitor or its products or services.


B.2. Anti-Corruption: Offering and Granting Advantages

We compete fairly for orders with thequality and the price of our innovativeproducts and services, not by offeringimproper benefits to others. As a result,no employee may directly or indirectly of-fer, promise, grant or authorize the giv-ing of money or anything else of value toa government official to influence officialaction or obtain an improper advantage.The same applies to a private commercialcounterparty in a business transaction inconsideration for an improper advantage.Any offer, promise, grant or gift mustcomply with applicable laws andSiemens’ policies, and must not raise anappearance of bad faith or unsuitable-ness. This means that no such offer,promise, grant or gift may be made if itcould reasonably be understood as an ef-fort to improperly influence a govern-ment official or as a bribe to a commer-cial counterparty to grant Siemens abusiness advantage.

The term government official is definedbroadly to include officials or employeesof any government or other public body,agency or legal entity, at any level, in-cluding officers or employees of state-owned enterprises and public interna-tional organizations. It also includescandidates for political office, politicalparty officials and employees, as well aspolitical parties.

In addition, employees may also not givemoney or anything of value indirectly(for example, to a consultant, agent, in-termediary, business partner or otherthird party) if the circumstances indicatethat all or part of may possibly be directlyor indirectly passed on to a governmentofficial to influence official action or ob-tain an improper advantage or to a pri-vate commercial counterparty in consid-eration for an unfair advantage in abusiness transaction.

For that reason, employees responsiblefor hiring consultants, agents, partners injoint ventures or comparable entitiesmust take action as appropriate to:

• ensure that those third parties un-derstand and will abide by Siemens’anti-corruption policies or compara-ble equivalents,

• evaluate the qualifications and re-putation of such third parties, and

• include appropriate provisions inagreements and contracts designedto protect Siemens.

This applies in particular, but not only ifthey have contact with government offi-cials on behalf of Siemens.

Finally, each investment decision madeby the Company – whether it is the pur-chase of a controlling interest in a com-pany or a minority interest, or a jointventure arrangement – must be based ona prior compliance check.


B.3. Anti-Corruption:Demanding and AcceptingAdvantages

Employees are not permitted to use theirjobs to solicit, to demand, accept, obtainor be promised advantages. This does notapply to the acceptance of occasionalgifts of purely symbolic value or meals orentertainment reasonable in value thatare consistent with local customs andpractices and Siemens policies. Any othergifts, meals or entertainment must berefused.

B.4. Political Contributions,Charitable Donations andSponsoring

Siemens does not make political contri-butions (donations to politicians, politicalparties or political organizations).

As a responsible member of society,Siemens makes monetary or productdonations for education and science, artand culture, and social and humanitarianprojects. Sponsorships for which Siemensreceives advertising are not considereddonations, nor are contributions to in-dustry associations or fees for member-ships in organizations that serve businessinterests.

Some donations are always prohibited,including donations

1. to individuals and for-profit organi-zations,

2. paid to private accounts,

3. to organizations whose goals areincompatible with Siemens’ corpo-rate principles, or

4. that would damage Siemens’ repu-tation.

All donations must be transparent. Thismeans, among other things, that the re-cipient’s identity and planned use of thedonation must be clear and the reasonand purpose for the donation must bejustifiable and documented. Quasi-dona-tions, meaning donations which appearto be compensation for a service but aresubstantially larger than the value of theservice, are prohibited as violating theprinciples of transparency.


Sponsoring means any contribution inmoney or in kind by Siemens towards anevent organized by a third party in returnfor the opportunity to advertise theSiemens brands by, for example, display-ing the Siemens logo, being mentionedin the opening or closing addresses, orthe participation of a speaker on a dis-cussion panel, as well as tickets to theevent.

All sponsoring contributions must betransparent, pursuant to written agree-ment, for legitimate business purposes,and commensurate with the considera-tion offered by the event host.

Contributions may not be promised, of-fered or made to secure unjustified com-petitive advantages for Siemens or forother improper purposes, and they maynot be made towards events organizedby individuals or organizations that havegoals incompatible with Siemens’ corpo-rate principles or that would damageSiemens’ reputation.

B.5. GovernmentProcurement Siemens competes for contracts fromgovernment entities and government-owned businesses around the world. Inall of Siemens’ dealings and interactionswith governments, we act in a mannerthat is transparent, honest and accurate.

We comply with all applicable laws andregulations related to government pro-curements, including laws prohibitingefforts to improperly influence govern-ment officials.

B.6. Anti-moneyLaundering Money laundering is the process of dis-guising the nature and source of moneyconnected with criminal activity – suchas terrorism, drug trafficking or bribery –by integrating dirty money into thestream of commerce so that it appearslegitimate or its true source or ownercannot be identified.

It is Siemens’ objective to conduct busi-ness with reputable customers, consul-tants and business partners who are in-volved in lawful business activities andwhose funds are derived from legitimatesources. We do not facilitate money laun-dering. All employees must abide by ap-plicable anti-money laundering laws andSiemens’ procedures, such as finavi-gate®, designed to detect and deter sus-picious forms of payment or customersor other transactions that could involvemoney laundering. To avoid problems inthis area, employees must be attentive toand report suspicious behavior by cus-tomers, consultants and business part-ners. Employees must also follow all ac-counting, record-keeping and financialreporting requirements applicable tocash and payments in connection withother transactions and contracts.


B.7. Trade Controls

Siemens complies with applicable exportcontrols and customs laws and regula-tions in the countries where it does busi-ness. Export controls generally apply tothe transfer of goods, services, hardware,software or technology across certain na-tional borders, including by email. Exportcontrol laws may be triggered in connec-tion with direct or indirect exports to orimports from sanctioned countries orparties, who, for example, may be desig-nated based on national security groundsor because of participation in criminal ac-tivity. Violations of these laws and regu-lations may lead to serious penalties, in-cluding fines and governmentalwithdrawal of simplified import and ex-port procedures (interruption of seamlesssupply chain).

Employees involved in the import and ex-port of goods, services, hardware, soft-ware or technology as described abovemust follow applicable economic sanc-tions, export control and import laws andregulations and any related policies andprocedures established by the business inwhich they work.

B.8. Working with Suppliers

Siemens as a company expects its suppli-ers to share Siemens’ values and complywith all applicable laws. Furthermore,Siemens expects its suppliers to act in ac-cordance with the following principles,similarly adopted by Siemens, concerningresponsibilities vis-à-vis stakeholders andthe environment:

• Comply with all applicable laws,

• prohibit corruption,

• respect basic human rights of em-ployees,

• comply with laws prohibiting childlabor,

• take responsibility for the healthand safety of their employees,

• act in accordance with applicablestatutory and international stan-dards regarding environmentalprotection, and

• promote compliance among theirsuppliers with Siemens’ Code ofConduct for Suppliers.


C. Avoiding Conflicts ofInterest

It is the duty of Siemens employees tomake business decisions in the best inte-rest of Siemens, not based on their ownpersonal interests. Conflicts of interestarise when employees engage in activi-ties or advance personal interests at theexpense of Siemens’ interests.

Employees must inform their supervisorof any personal interest they could possi-bly have in connection with the execu-tion of their professional duties.

Employees are not permitted to use, fortheir own personal contracts or orders,companies with which they have busi-ness dealings as part of their activities forSiemens if they could derive any advan-tage from the personal contract or order.This is particularly applicable if the em-ployee exercises or is capable of exercis-ing a direct or indirect influence uponwhether that company receives a con-tract from Siemens.

A conflict can take the form of a businessrelationship with, or an interest in, acompetitor or customer of Siemens, orparticipation in sideline activities thatprevent employees from being able tofulfill their responsibilities at Siemens. Itis important that all employees recognizeand avoid conflicts of interest, or eventhe appearance of a conflict of interest,as they conduct their professional activities.

C.1. Competing withSiemensAn employee may not operate or assist acompany that competes with Siemens orengage in any competing activities.

C.2. Sideline Work

Employees may not engage in sidelinework that competes with Siemens. Beforeemployees may engage in other sidelinework for remuneration they must notifySiemens and seek written permission.Occasional writing activities, lectures,and comparable occasional activities arenot considered sideline work. Permissionwill not be granted if it is detrimental tothe interests of Siemens. Permission maybe refused if employees have dealings inthe course of their official Siemens’ du-ties with the company in question. Previ-ously granted permission may be revokedon these grounds as well.

C.3. Interests in ThirdCompanies Employees who directly or indirectly holdor acquire a stake in a competitor compa-ny, must disclose this fact to their person-nel department if this stake gives themthe opportunity to exert influence on themanagement of that company. It can beassumed, as a general rule, that the possi-bility of exerting influence on the man-agement exists when a stake exceeds 5 %of a competitor company’s total capital.


Employees who directly or indirectly holdor acquire an interest in a Siemens businesspartner or a company in which Siemenshas ownership shares also have to disclosethis fact to the personnel department re-sponsible, if they have dealings with thebusiness partner or company in the courseof their official duties or if they will hold aposition in that company. For shares in list-ed companies, this applies only if the inter-est exceeds 5% of total equity.

Once an interest in a third company hasbeen disclosed, the Company may takesuitable measures to eliminate any con-flict of interest.


D. Handling of CompanyProperty

There are many devices and pieces ofequipment in Siemens offices andworkshops, such as telephones, copyingmachines, computers, software, Inter-net/Intranet, machines and other tools,including e-mail and answering machinesystems. These are only to be used forCompany business and not for personalgain. Exceptions, and payment if applica-ble, can be agreed upon locally, providedthat the use of Siemens property doesnot:

• relate to any illegal activity,

• cause an actual or perceived conflictof interest, or

• lead to significant added costs, dis-ruption of Siemens business or oth-er adverse effects for the Company,including by interfering with an em-ployee’s assigned duties or the as-signed duties of other employees.

In no case may information be retrievedor transmitted that furthers or incitesracial hatred, glorification of violence orother criminal acts, or contains materialwhich is sexually offensive within the re-spective culture.

Employees are not permitted without theconsent of their supervisor to makerecords, files, video or audio recordings,or reproductions using Siemens equip-ment or facilities if the activity is not di-rectly related to Company business.


E. Handling of Information

E.1. Records and FinancialIntegrityOpen and effective communication re-quires accurate and truthful reporting.This applies equally to relationships withinvestors, employees, customers andbusiness partners, as well as with thepublic and all governmental offices.

Siemens is also required to maintainsound processes and controls so thattransactions are executed according tomanagement’s authorization. Siemensmust also prevent and detect unautho-rized use of Siemens assets. All Siemensemployees are required to make sure that the Siemens books and records theycreate or are otherwise responsible forare:

• complete,

• accurate,

• honestly reflect each transaction orexpenditure, and

• are timely and in accordance withapplicable accounting rules andstandards

whether or not the information will beincluded in a public filing or provided toa government agency. Such books andrecords include all data, certificationsand other written materials provided forfinancial reporting and disclosure pur-poses as well as materials collected for

other purposes. These also include inter-nal expense records (such as expense ac-count reports).

E.2. Confidentiality

Confidentiality must be maintained withregard to Siemens’ internal confidentialor proprietary information that has notbeen made known to the public. Non-public information from or concerningsuppliers, customers, employees, agents,consultants and other third parties mustalso be protected in accordance with le-gal and contractual requirements.

Confidential or proprietary informationmay include, in particular:

• details concerning a company’s or-ganization and equipment, prices,sales, profits, markets, customersand other matters of business,

• information on manufacturing orresearch and development, and

• internal reporting figures.

The obligation to maintain confidentialityextends beyond the termination of therelevant relationship, since the disclosureof confidential information could causeharm to Siemens’ business, clients or cus-tomers no matter when it is disclosed.


E.3. Data Protection andData Security Access to the Intranet and Internet,worldwide electronic information ex-change and dialogue, and electronicbusiness dealings are all crucial to the ef-fectiveness of each and every one of us,and for the success of the business as awhole. However, the advantages of elec-tronic communication are tied to risks interms of personal privacy protection anddata security. Effective foresight with re-gard to these risks is an important com-ponent of information technology man-agement, the leadership function, andalso the behavior of each individual.

Personal data may only be collected,processed, or used insofar as it is neces-sary for pre-determined, clear, and legiti-mate purposes. In addition, personaldata must be maintained in a securemanner and appropriate precautionsshould be taken when transmitting it.High standards must be ensured withregard to data quality and technical pro-tection against unauthorized access. The use of the data must be transparentfor those concerned and the rights ofthose concerned must be safeguardedwith regard to use and correction of in-formation and, if applicable, to objec-tions pertaining to blocking, and deletionof information.

In some jurisdictions (such as the Euro-pean Union) there are strict laws and reg-ulations pertaining to the collection anduse of personal data, including data onothers, such as customers or businesspartners. All employees must abide bysuch laws, to the extent they are applica-ble, to protect the privacy of others.

E.4. Insider Trading Rules

People who have inside information withregard to Siemens or another company,such as a customer, supplier or joint ven-ture partner whose securities are admit-ted to trading on a stock exchange or anorganized securities market, are not al-lowed to trade in these companies’ secu-rities or in financial instruments theprices of which depend directly or indi-rectly on these companies’ securities (in-sider securities).

Inside information is any specific infor-mation which is not public knowledge re-lating to Siemens or such other issuer ofinsider securities, which, if it becamepublicly known, would likely have a sig-nificant effect on the price of the insidersecurity. Such likelihood exists if a rea-sonable investor would view the informa-tion as likely to have an impact on theprice of the security. It would also exist ifa reasonable investor would take the in-formation into account in making an in-vestment decision.

Inside information may be acquired as aresult of an employee’s position and re-sponsibilities or inadvertently, and in-cludes non-public information aboutsuch things as:

• financial results,

• financial plans or budgets,

• dividend changes,

• significant mergers or acquisitions,

• divestitures,

• particularly important contractawards or strategic plans,

• major developments in litigation,

• technical or product developments,

• major management changes, jointventures and major business agree-ments, or

• business relationships.

In order to avoid even the appearance ofa violation of the insider trading rules bythe members of the uppermost manage-ment level, these individuals may gener-ally effect no transactions in Siemens’ se-curities in the time from two weeks priorto the end of a quarter or fiscal year untiltwo days subsequent to publication ofquarterly or fiscal-year-end results.


The same applies to employees ofSiemens whose activities or functiongives them access to financial results orother material information that is not yetpublic. Inside information must not bedisclosed or made available to a thirdparty without authority to do so.

The disclosure of inside information isunauthorized whenever it is made out-side the normal scope of an insider’swork functions or professional duties, orin fulfilling other duties on behalf of theissuer. This applies both to informationdisclosed within Siemens and to informa-tion disclosed outside Siemens, includingto journalists, financial analysts, custo-mers, consultants, family members, orfriends. Furthermore, employees must al-ways make sure that insider-relevant in-formation is secured or kept under lockand key so that unauthorized personscannot gain access to it.

Persons who have inside information arenot allowed to recommend that a thirdparty acquire or dispose securities forwhich that information is relevant, or tootherwise induce a third party to do so.

Managers can be held personally liablefor damages in some cases if an employeeviolates insider trading rules and propersupervision could have prevented theviolation.

Additional or special insider trading rulesand local law have to be complied with,as applicable.


F. Environment, Safety andHealth

F.1. Environment andTechnical SafetyProtecting the environment and conser-ving natural resources are high prioritiesfor our Company. Through managementleadership and employee commitment,Siemens strives to conduct its operationsin a manner that is safe for the environ-ment and continually improves environ-mental performance. A worldwide envi-ronmental management system has beenimplemented by Siemens to ensure ob-servation of the law and sets high stan-dards for this purpose. Beginning at theproduct development stage, environmen-tally compatible design, technical safetyand health protection are fixed as targets.

All employees must contribute to thesegoals through their own behavior.

F.2. Work Safety

Protecting the health and safety of em-ployees in the workplace is a high priorityfor Siemens. It is the responsibility ofeveryone to foster Siemens’ efforts toconduct its operations in a safe manner.The responsibility vis-à-vis employeesrequires the best possible accident-prevention measures, and applies to:

• the technical planning of work-places, equipment and processes,

• safety management, and

• personal behavior in the everydayworkplace.

The work environment must conformto the requirements of health-orienteddesign.

All employees must constantly be atten-tive to work safety.


G. Complaints andComments

All employees may lodge a complaintwith their supervisor, their complianceofficer, personnel manager or some oth-er person/unit designated for this pur-pose or with an existing internal workscouncil.

Circumstances which point to a violationof the Business Conduct Guidelines are to be reported to the Chief ComplianceOfficer, the Compliance Officer responsi-ble for the Sector, Division, Regional orCorporate Units, the Tell Us Helpdesk orthe Siemens Ombudsman.

There is a special process for handlingcomplaints related to accounting prac-tices.

All complaints can be submitted bothconfidentially and anonymously, and allcomplaints will be investigated. Correc-tive measures will be implemented ifnecessary.

All documentation will be kept confiden-tial to the extent permitted by law. Noreprisal of any kind against complainantswill be tolerated.


H. Compliance Implemen-tation and Monitoring

The management of Siemens throughoutthe world shall actively foster the wide-spread distribution of the Business Con-duct Guidelines and see to it that theyare implemented.

Compliance with the law and observanceof the Business Conduct Guidelines shallbe monitored worldwide in all Siemenscompanies on a regular basis. This shallbe done in accordance with applicablenational procedures and legal provisions.

An extensive compliance organization isin place at the level of Siemens, the Sec-tors, Divisions and Regions to ensure thatthe Siemens compliance program is en-forced.


Further Informationand Contacts

Integrity is at the heart of all our actions.These Guidelines define what integritymeans for our business. But they can’ttell the whole story or answer everyquestion.

Siemens’ Compliance Intranet Web Site � https://cpps.eps.siemens.com/irj/portal/ep/public/en/complianceprovides additional information – inclu- en/compliance/ombudsman.htmding company-wide, frequently askedquestions, training materials and otheraids – that add content-related specificsto these Guidelines.

If a Siemens employee is not sure whatthe right thing to do is in a specific case,there are many sources of informationavailable to help, including the employ-ee’s supervisor, Sector, Division, Regionalor Corporate Compliance Officer and theCompliance Helpdesk’s Ask Us, which isavailable on the Siemens Intranet � https://xenios.os.fth.sbs.de/compliance/question.do?dispatchAction=new.

Moreover, if an employee has discovereda case of possible misconduct, variousoptions are available to report it. Theseinclude not only an employee’s supervi-sor and compliance officer but also theCompliance Helpdesk’s Tell Us, nowavailable 24/7 by phone and external In-ternet, and the Siemens Ombudsman. � http://w1.siemens.com/responsibility/

https://cpps.eps.siemens.com/irj/portal/ep/public/en/compliance

https://xenios.os.fth.sbs.de/compliance/question.do?dispatchAction=new

http://w1.siemens.com/responsibility/en/compliance/ombudsman.htm


Appendix

Conventions andRecommendations ofInternationalOrganizations

In addition to the laws and regulations ofindividual countries, there are a numberof Conventions and Recommendationsfrom international organizations whichare noteworthy. Although these docu-ments are primarily addressed to MemberStates and not directly to companies, theynevertheless function as important guide-lines for the conduct of multinationalcompanies and their employees. Siemenssupports the requirements of these con-ventions and recommendations.

Siemens is a member of the UnitedNations Global Compact and regards itsten principles, as well as the rules laiddown in the framework agreement of theInternational Metalworkers´ Federation(IMF), as binding for the entire Company.Otherwise, the Company´s internal arbi-tration arrangements apply.

Siemens is also committed to embracing,supporting and enacting, within its furthersphere of influence, the set of core valuesin the areas of human rights, labor stan-dards, the environment, and anticorrup-tion included therein as an integral partof its business strategy and operations.

In line with its Global Compact commit-ment Siemens therefore expects its em-ployees, suppliers and business partnersaround the globe to recognize and applyparticularly the standards of the:

• Universal Declaration of HumanRights (1948) and European Con-vention for the Protection of HumanRights and Fundamental Freedoms(1950)

• ILO (International Labor Organiza-tion) Tripartite Declaration of Princi-ples concerning Multinational Enter-prises and Social Policy (1977) andILO Declaration on FundamentalPrinciples and Rights at work (1998)(specially with following issues:elimination of child labor, abolitionof forced labor, prohibition of dis-crimination, freedom of associationand right to collective bargaining)

• OECD Guidelines for MultinationalEnterprises (2000)

• Agenda 21 on Sustainable Develop-ment (final document of the basicUN-conference on environment anddevelopment, Rio de Janeiro (1992)

• UN Convention Against Corruption(2005)


Note

The following definitions explain key terminology from the Business Con-duct Guidelines, with the aim of ensur-ing better understanding of the Busi-ness Conduct Guidelines.

However, the definitions given are not legal definitions applicable as such throughout Siemens. It should be noted that terminology may also be applied differently in different coun-tries and cultures, which is why local conditions must also always be taken into consideration.

Business Conduct Guidelines January 2009

Glossary

Business Conduct Guidelines, Edition 2009-01 29

U"Agenda 21" on Sustainable Development UAnti-trust laws UAsk us helpdesk UAward procedure UBribery UBusiness partners UCartel UChild labor UCompetition law UCompliance UConfidentiality UConflict of interest UCorruption UData protection UData security UDelegation UDiscrimination UDonation UEnvironmental protection UExport controls UFinancial reporting UGovernment official UHuman rights UInsider securities UIntegrity UInternational Labour Organization (ILO) UInternational Metalworkers’ Federation UMoney laundering UOccupational health and safety UOECD Guidelines for Multinational Enterprises UOmbudsman UPersonal data UPersonal rights UPrice agreement USecrecy USideline work USiemens Business Conduct Guidelines USponsorship USuppliers

UTechnical safety UTell us helpdesk UTrade controls UUN Convention against Corruption UUN Global Compact UWhistleblower hotline UWork safety

Definitions


Definitions

"Agenda 21" on Sustainable Devel-opment

Agenda 21 is a plan of action in environment and development policy, adopted at the United Nations Conference on Environment and Development held in Rio de Janeiro in 1992. It covers all major policy areas of environmentally compatible and sustainable development. Agenda 21 is applicable for both industrial and developing countries. It contains important stipulations in areas such as the combating of poverty, population policy, trade, the environment, waste, chemicals, climate and energy policy, agricultural policy, and the financial and technological cooperation between industrial and developing countries. Siemens backs and supports the stipulations set out in Agenda 21 and expects its employees, suppliers, and business partners to comply therewith.

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Anti-trust laws

Anti-trust laws are rules of competition that apply for restrictive agreements and business practices, and prohibit the improper exploitation of a domi-nant market position.

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Ask us helpdesk

One of the two compliance helpdesks run by Siemens. Siemens employees can contact this helpdesk 24/7 with queries on compliance issues. Consult-ing with other experts, the helpdesk team makes sure the queries are an-swered competently. This service gives employees the chance to seek clarifica-tion on compliance-related issues in advance.

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Award procedure

Procedure to be adhered to when awarding contracts particularly public contracts, and defined by the corre-sponding rules and provisions in legis-lation governing the award of con-

tracts. This is a way to ensure that the resources are deployed as economi-cally as possible and the interested companies are given the opportunity to be granted public contracts in a fair competition. Certain infringements of competition rules, such as 4Ubribery H, infringement of the obligation of non-disclosure, and 5Uprice agreements H are criminal offences and may lead to significant damage on the part of the contractor as well as customer.

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Bribery

Bribery is the prohibited offering, promising or granting of advantages (e.g. gifts of money) to government officials or people in comparable posi-tions, so that they carry out an official act in return and thus violate their official duties (referred to as active bribery). Influencing an official act, without official duties being violated, is also punishable in most legal sys-tems, e.g. as offering an undue advan-tage. If a government official de-mands, accepts, or secures the prom-ise of advantages in return for per-forming an act that violates their offi-cial duties, they are guilty of passive bribery or accepting an advantage. Bribery and corruption in business transactions at home or abroad (pri-vate sector employees) are likewise liable to be punished.

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Business partners

Business partners as referred to in the Business Conduct Guidelines are third parties for whose actions Siemens may be held liable where applicable under individual legal systems. Examples include sales representatives, sales-related consultants, customs agents, and consortium partners. Siemens is therefore required to carry out careful checks on the integrity of business partners. Detailed definitions and rules are set out in Circular V 16/2008 (Co-operation with business partners – Integrity review and contract provi-sions).

5Uhttps://circulars.siemens.com/content/circulars/ca/DocLib/CircularsDocLib/V-CR-16-2008.pdf

https://circulars.siemens.com/content/circulars/ca/DocLib/CircularsDocLib/V-CR-16-2008.pdf


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Cartel

Refers to agreements between com-petitors with the aim of restricting competition, e.g. by controlling prices or carving up markets.

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Child labor

Child labor is the deployment of chil-dren as workers. Siemens is guided by the age limits defined by the

5UInternational Labour Organization (ILO) H. Siemens only accepts the de-ployment of workers who are at least 15 years of age, or if a higher age limit applies in a country, then this age limit is complied with. Siemens only accepts a minimum age of 14 years by way of exception, if a statutory minimum age of 14 years applies in the country in which the work is being performed, based on ILO Convention no. 138.

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Competition law

General generic term for the law against unfair acts of competition (= traditional competition law in its nar-rowest sense, governed in Germany by the Unfair Competition Act (UWG)) and the law against restrictive prac-tices (= anti-trust law, governed in Germany by the Act against Restraints on Competition (GWB)).

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Compliance

Compliance at Siemens means comply-ing with all regulations that govern our behavior – including vis-à-vis ex-ternal stakeholders. These can be external laws and regulations and/or internal guidelines, procedures and controls. Internal guidelines corre-spond to external provisions, but also take the values of the company into consideration. It therefore involves instilling Siemens values and turning ethical conduct into a competitive advantage. These values are: Respon-sible – excellent – innovative.

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Confidentiality

Confidential information is only pro-vided for a restricted group of persons. It is prohibited to publish and forward such information to unauthorized parties. For Siemens internal confiden-tial or proprietary information secrecy is required.

Confidential or proprietary information includes:

• Details concerning a company’s organization and equipment, prices, sales, profits, markets, cus-tomers, and other matters of business,

• Information on manufacturing or research and development; and

• Internal reporting figures.

The obligation to maintain secrecy shall extend beyond the termination of the employment relationship.

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Conflict of interest

This is a situation in which a particular conflict arises because a person is forced to choose between two or more incompatible interests. This situation will arise for a person particularly if they pursue different interests in dif-ferent functions. From the perspective of professional ethics, the conflict cannot be tolerated, as this would be counterproductive in the sense of prevailing values.

A Siemens employee has a conflict of interest if a personal interest prevents them from making the best possible decision as a Siemens employee which means in the interest of Siemens. For example: If an employee privately engages a service-provider that also performs work for Siemens, and if this employee is also involved in engaging the services of this company for Sie-mens, he/she may not under any cir-cumstances accept personally favor-able terms and conditions. A situation like this sets the employee’s personal interest of saving money in conflict with the interest of Siemens to award contracts on the basis of independent assessments. In such a scenario, it would be easy to overstep the mark toward 6Ucorruption H.


6Up Siemens employees are obliged to avoid conflicts of interest.

Corruption

In legal terms, corruption is the abuse of a position of trust in government, the judiciary, politics, the private sector, or even non-economic associations or organizations, for example foundations, in order to achieve a material or immaterial advantage to which there is no lawful entitlement. There are individual statutory offences under the generic term of corruption, such as bribery and corruptibility, accepting an advantage, and granting an advantage.

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Data protection

These days, data protection is usually understood as protecting one’s right of self-determination with respect to information, i.e. the right of each individual to generally make their own decision about how their 6Upersonal data H is acquired and handled. The aim is to avoid and restrict the processing of this data to the requisite extent and to prevent it from being misused. Within the scope of data protection, it is therefore necessary to ensure that:

• Personal data is only collected, processed, or used insofar as it is necessary for predetermined, clear, and legitimate purposes (principles of earmarking, data re-duction and data economy);

• Personal data is handled transpar-ently for those involved, their rights to notification and informa-tion and where necessary objec-tion, blocking, and deletion are safeguarded (principle of direct acquisition; right to self-determination with respect to in-formation);

• Personal data is always safe-guarded against loss, destruction, and unauthorized access by taking appropriate technical and organ-izational measures. 6UData securi-ty H).

The significance of data protection has greatly increased with the develop-

ment of information and communica-tion technology, interconnected net-works, and growing data acquisition and storage.

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Data security

As an aspect of 6Udata protection H, data security describes the technical and organizational measures to be taken to protect personal data from loss, destruction, and unauthorized access, and to generally meet the requirements of data protection law. It is often used synonymously in compa-nies with the term “IT security” and relates to all corporate data that is not in the public domain, including pro-tecting the IT infrastructure from sabo-tage and misuse.

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Delegation

Delegation means the transfer of deci-sion-making competence from one unit to one or more other units or offices that are usually lower in hierar-chy to the first. However, a delegation is not dependent on existing hierarchi-cal levels. With the delegation of tasks, the company is obliged to ensure that the employee is capable and qualified to carry out the task transferred to them.

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Discrimination

Discrimination here refers to social discrimination, i.e. disadvantaging or disparaging individuals or groups on the basis of specific criteria. Siemens expressly does not tolerate any dis-crimination on the basis of ethnic background, culture, religion, age, disability, race, sexual identity, world view, and gender.

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Donation

Siemens understands the term dona-tion to mean voluntary payments (gifts of money or payments in kind) for cultural, scientific, or humanitarian objectives granted by the company to third parties without requiring any-thing in return, as well as contribu-


tions for memberships in social and cultural associations.

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Environmental protection

Environmental protection describes the protection of the environment from harmful influences or impact, such as environmental pollution and global warming, as well as the respon-sible handling of raw materials and other resources. The aim of environ-mental protection is to preserve the living environment of human beings and their health. At Siemens, envi-ronmental protection includes:

• Industrial environmental protec-tion covering environmental man-agement, waste management, and the protection of air, soil, and water.

• Product-related environmental protection including environmen-tally compatible product design, product recycling and reuse, and the avoidance of dangerous sub-stances in products and produc-tion.

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Export controls

Export controls generally apply to the transfer of goods, services, hardware, software, or technology across certain national borders, including by elec-tronic means. Export control laws may be triggered in connection with direct or indirect exports to or imports from sanctioned countries or parties, who, for example, may be designated based on national security grounds or be-cause of participation in criminal activ-ity. Export controls are governed by various laws at national and interna-tional level. See 7Utrade controls H.

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Financial reporting

A difference is made between external and internal financial reporting.

Internal financial reporting is under-stood to be the communication and publication of accounting data and key financial figures on a regular basis within the company.

External financial reporting is under-stood to be the communication and publication of the company’s financial data in the public arena on the basis of legal requirements and relevant capital market guidelines. For companies listed on the stock-exchange, this generally includes the publication of the company’s annual report, six-monthly report, and quarterly report, as well as other reporting duties, such as the ongoing notification of changes in significant corporate interests or upkeep of an insider list.

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Government official

The term “government official” gener-ally means a person who holds an official post and carries out official activities. However, there are some-times significant differences from country to country as to which posi-tions are considered to be official.

The Siemens Business Conduct Guide-lines define the term "government official” as “officials or employees of any government or other public body, agency or entity, at any level, includ-ing officers or employees of state-owned enterprises and public interna-tional organizations. It also includes candidates for political office, political party officials, and employees, as well as political parties.”

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Human rights

Every person is equally entitled to human rights, regardless of their race, color, gender, language, religion, po-litical and other beliefs, national or social background, descent, or other criteria. Human rights are indivisible, in other words they must be realized in their entirety. The internationally adopted source is the United Nations Universal Declaration of Human Rights (1948). Countries are primarily bound to actively safeguard human rights and grant effective legal protection against their infringement. For companies, the ethical obligation of not infringing any human rights through the company’s activities or being complicit in infring-ing human rights is now widely ac-cepted.


7Up Within its sphere of influence, Siemens undertakes to observe and support human rights in accordance with the United Nations Universal Declaration of Human Rights and the European Convention for the Protection of Hu-man Rights and Fundamental Free-doms adopted in 1950. Siemens ex-pects the same of its suppliers and business partners.

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Insider securities

Insider securities are securities that are not to be handled by exploiting inside information.

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Integrity

Integrity involves the general harmony between moral values and their appli-cation in real life. Integrity evokes characteristics such as sincerity, re-spectability, incorruptibility, trustwor-thiness, sense of justice, and civil courage. On the one hand, integrity is something for which a person or or-ganization is responsible. But on the other, it also depends on the good conduct of others and social living conditions.

At Siemens, integrity is central to how we think and act. To this end, all em-ployees are to let their common sense and good power of judgment prevail.

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International Labour Organization (ILO)

The International Labour Organization (ILO) is a special organization set up by the United Nations. The ILO’s work focuses on formulating and enforcing international labor and social stan-dards, supporting the development of globalization in a fair and socially just way, and creating work in conditions of human dignity as a core require-ment for combating poverty.

International Metalworkers’ Federa-tion

The International Metalworkers’ Fed-eration (IMF) is a federation of na-tional unions in the metal industry at

world level. It represents the collective interests of metalworkers in more than 200 unions in 100 countries. The un-ion representing Germany is IG Metall.

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Money laundering

Money laundering is operated with the aim of channeling “dirty” money, originating from criminal activities such as terrorism, drugs trafficking or bribery, into legal financial and eco-nomic circulation, thus turning it into "clean" money, i.e. it has been "laun-dered". The actual origin of the money or identity of the owner is intended to be concealed through various meas-ures, such as cash payment of large sums or complex transactions via dummy corporations.

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Occupational health and safety

This relates to the protection of em-ployees from occupational risks and harmful workloads (insufficient and excessive demands placed on employ-ees). Risks impact on employees in the form of personal damage (injuries, occupational diseases, and other dam-age to health) and harmful workloads in the form of harmful stress or strain (too much or too little).

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OECD Guidelines for Multinational Enterprises

The Organisation for Economic Co-Operation and Development (OECD) brings together the governments of thirty countries around the world committed to democracy and the mar-ket economy. The objectives of the OECD include supporting sustainable economic growth and assisting with other countries’ economic develop-ment. The OECD Guidelines for Multi-national Enterprises provide principles and standards in a variety of areas including employment and industrial relations, protection of environment, consumer interests, fair competition, and combating corruption. They de-fine responsible business conduct and form a significant benchmark around the world for good corporate man-agement and control. Complaints


concerning infringements can be lodged at National Contact Points.

Siemens backs and supports the stipu-lations set out in the OECD Guidelines and expects its employees, suppliers, and business partners to comply therewith.

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Ombudsman

An ombudsman is the person who takes on the role of an impartial refe-ree within an organization or com-pany. This role may also be assumed by an external person or organization to ensure the greatest possible impar-tiality. The ombudsman tries to find a solution in disputes, taking into con-sideration the interests of all parties involved.

At Siemens, all employees, including external parties, have the option of reporting possible infringements of the Business Conduct Guidelines to the

8UTell Us helpdesk H or Siemens om-budsman. This is possible confiden-tially and anonymously.

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Personal data

Personal data is information on a per-son’s private or material conditions, i.e. information and data that can be assigned to a person. The term is to be interpreted broadly and comprehen-sively – it is not necessary to provide a precise description (e.g. name of per-son), the possibility of assigning the data and determining a person suf-fices. Whether a person is to be inter-preted as a natural and/or legal person can vary from country to country. The object of 8Udata protection H is to safe-guard such persons from having their data infringed.

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Personal rights

Personal rights involve the statutory rights to which a person is specifically entitled, including the right to per-sonal safety, personal freedom, or private property. This includes rights to intellectual property (e.g. copyright or patent rights). Personal rights are based on 8Uhuman rights H. Unlike with

human rights to which each person is equally entitled, with personal rights there are differences in scope and form based on the respective legal system applicable for the individual.

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Price agreement

These are agreements between manu-facturers or customers of goods or services to adhere to a specific price level. Price agreements are prohibited as “hard-core cartels” and subject to fines.

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Secrecy

9U Confidentiality

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Sideline work

Sideline work is work performed by an employee in addition to his or her main occupation. It may not impinge on the main occupation or lead to a 9Uconflict of interests H for the employee. Siemens must be notified of any side-line work that is performed in return for payment; such work requires its prior written consent.

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Siemens Business Conduct Guidelines

These guidelines are a set of rules setting out the ethical and legal framework within which Siemens is to act. They contain the basic rules and principles for our conduct within our company and in relation to our exter-nal partners and the general public. They define how we perceive our ethi-cal and legal responsibility as a com-pany and also contain specific re-quirements for instance for complying with competition law and anti-corruption law, handling donations, avoiding conflicts of interest when carrying out our work, complying with the prohibition of insider trading, and protecting company assets. The Busi-ness Conduct Guidelines form the core of the compliance program as a cen-tral code of conduct, and are binding on all employees Siemens-wide.


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Sponsorship

Sponsorship is a contribution in the form of money or in kind by a sponsor, e.g. a company, for an event organized by third parties. Unlike with

9Udonations, H with sponsoring some-thing is granted in return for the con-tribution. The sponsor may usually advertise their brands within the scope of the event and/or be given the op-portunity in some other way to sup-port its marketing goals.

The following is applicable for Sie-mens: All sponsoring contributions must be transparent, pursuant to writ-ten agreement, for legitimate business purposes, and commensurate with the consideration offered by the event host.

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Suppliers

A supplier provides Siemens with goods (direct materials), specific per-formance and services (indirect mate-rials), and capital goods (invest).

In bookkeeping terms, the supplier is a creditor to whom payments are owed.

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Technical safety

At Siemens, technical safety involves:

• Radiation safety (including protec-tion against ionizing and non-ionizing radiation)

• Transport of dangerous goods • Technical risk management in-

cluding fire protection and indus-trial disaster prevention

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Tell us helpdesk

One of the two compliance helpdesks run by Siemens. Siemens employees and other persons may report possible infringements of the Business Conduct Guidelines to this helpdesk 24/7 either online or by telephone. The call center and website are managed by an exter-nal service provider specializing in the secure, confidential handling of sensi-tive issues. Incoming messages are not traced back and the sender is not auto-

matically registered. The “Tell us” helpdesk acts as a useful extension to the 1Uombudsman H, as an additional channel at international level.

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Trade controls

Trade controls refer to all statutory restrictions to trade imposed by a country for importing and exporting

1Uexport controls H goods. These in-clude, for example, customs provi-sions, packaging provisions, certifica-tion provisions, etc. Trade controls may have different objectives and underlying reasons, for example em-bargos, protection of endangered species, environmental protection, protection of own economy, etc.

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UN Convention against Corruption

The United Nations Convention against Corruption (also referred to as UNCAC) adopted on October 31, 2003 requires its signatories to punish vari-ous forms of corruption involving government officials and ensure coop-eration at international level. The Convention came into force on De-cember 14, 2005. Siemens backs and supports the stipulations set out in the United Nations Convention against Corruption and expects its employees, suppliers, and business partners to comply therewith.

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UN Global Compact

Global Compact is a United Nations strategic policy initiative for businesses that are committed to aligning their operations and strategies with ten universally accepted principles in the areas of human rights, labor, environ-ment, and anti-corruption. The aim of the UN Global Compact is to foster the social commitment of companies so that business can contribute to coun-tering the challenges to globalization. Siemens joined the Global Compact in 2003, and is committed to the initia-tive in a number of different areas. The ten principles of the Global Compact are basic binding rules governing our corporate actions.


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Whistleblower hotline

Whistleblowing is understood to mean bringing attention to grievances, ille-gal acts, or general risks. A synonym for "whistle blowing" could be “raising the alarm”.

At Siemens, the 1UTell us compliance helpdesk Hand 1Uombudsman H fulfill the role of a whistleblower hotline. In this way, our employees – and external parties – are given the option of re-porting possible grievances confiden-tially and anonymously. In addition, further support on this topic is pro-vided on the intranet.

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Work safety

Work safety is a necessary prerequisite of performing any work. The Techni-cal, Organizational and Personal re-quirements (T.O.P. / measures hierar-chy) of work are taken into considera-tion to ensure safe working. Work safety is achieved by taking 1U occupa-tional health and safety H measures.

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www.siemens.com

Imprint

Publisher:Siemens AGCorporate Compliance Office (CL CO)Wittelsbacher Platz 280333 München

For the publisher:Dr. Andreas Pohlmann

Further information and requests:Siemens Compliance [email protected]

Edition:January 2009

Editorial Office:Siemens CL CO PT

Copyrights:All rights, also that of translation, reprintand copy or parts thereof are reserved.No part of this work may be duplicated,reproduced, processed, distributed orpublished in any form (photo copy, CD-ROM, electronically, etc.) without thewritten consent of CSP. Changes tographics must be approved.

This document will not be recalled in theevent of any alterations.

[email protected]

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