3.1 Compliance and ethics Non-mandatory learning products in diverse formats are also Compliance indicators¹ presented in the form of learning paths in our global learning platform My Learning World. Fiscal year 2023 2022 The BCG training was rolled out to 190,000 employees Compliance cases reported 416 363 worldwide, and 129,000 of them (approximately 68%) had Disciplinary sanctions 166 212 successfully completed the training by the end of fiscal 2023. therein warnings 87 90 therein dismissals 43 74 therein other² 36 48 129,000 1 Continuing and discontinued operations. 2 Includes loss of variable and voluntary compensation components, transfer, and employees were trained on the content of suspension. our BCGs in fiscal 2023 We believe that the evidence demonstrates that our compliance system is well-designed and effectively implemented. Due to Siemens employees around the world also completed about the nature of our business operations, the environments 461,000 training programs for specific target groups in fiscal where we work, and our company’s geographic distribution, 2023.2 we do not regard the number of incidents as unusual. “Ethical corporate governance and More information on significant ongoing and future charges compliance are nonnegotiable. Our of corruption, antitrust violations, and other violations of the approach goes beyond strict law can be found in SIEMENS REPORT FOR FISCAL 2023, COMBINED compliance with laws and MANAGEMENT REPORT, CHAPTER 8.3.4 COMPLIANCE RISKS, AND NOTES TO CONSOLIDATED FINANCIAL STATEMENTS, NOTE 22 LEGAL PROCEEDINGS regulations by placing integrity at the center of our corporate culture Stakeholder involvement in our compliance and business processes.” approach Compliance-related questions are included in the annual CEO Roland Busch Siemens Global Employee Survey in order to evaluate the effectiveness of the compliance system within the company. Compliance indicators and whistle-blowers We also use the survey to acquire a better understanding of Our employees use our reporting channels regularly. A total the degree to which ethical conduct is embedded in our of 416 compliance cases that required an inquiry or investi- corporate culture. The results of last year’s survey show an 3 gation were reported in fiscal 2023. We believe that the increase in the already high approval rates relative to the increase in compliance cases from the previous year falls perception and awareness of integrity, ethics, and responsible within the range of normal fluctuation. The total number of business conduct throughout the organization. disciplinary measures imposed for compliance violations was 166 in fiscal 2023. The number of disciplinary measures in a fiscal year does not necessarily reflect the number of compliance cases reported in the same period. This is because disciplinary action may not be taken in the same year as the case was reported or when the investigation was completed. Furthermore, one compliance case may result in multiple disciplinary actions or none at all. 2 This figure includes Siemens Healthineers employees. 3 At the same time, the overall response rates decreased from 167,900 in fiscal 2022 to 161,550 in fiscal 2023. SIEMENS SUSTAINABILITY REPORT 2023 38
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