3.1 Compliance and ethics 3.1 Compliance and ethics – Zero­tolerance approach to breaches of applicable Our Compliance governance and policies laws and our internal guidelines The Siemens Compliance organization oversees our compli- – A global, risk­based compliance system ance system and is chaired by our Chief Compliance Officer, – Ethics and integrity are the basis for sustainable who is responsible for all legal and operational aspects of business practices compliance. The Compliance organization is part of Siemens global Legal and Compliance department. It is led by the General Counsel, who reports directly to our President and Management approach CEO. Operating with integrity and in compliance with laws and regulation is fundamental to stakeholder trust and our com- Siemens Chief Compliance Officer reports directly to pany’s continued success. Siemens and its roughly 320,000 Siemens’ CEO on functional matters, in addition to reporting employees operate in multiple countries around the world. to the Managing Board and the Siemens AG Supervisory Our customers in both the private and public sectors serve a Board on a quarterly and ad-hoc basis. vast array of industries. Our global business operations are governed by numerous national legal systems and take place Compliance Officers in the business ensure that our Compli- in a variety of political, social, and cultural settings that are ance system is implemented worldwide. They work closely constantly changing. Therefore, Siemens’ business and with employees and managers, who assume personal compliance environment is correspondingly complex. responsibility for compliance in their respective business units. The way that Siemens and our partners do business impacts the markets and societies where we operate. Unethical and We believe that it is necessary for the entire management unlawful conduct like corruption, cartel arrangements, and team to act on our commitment to compliance and ensure money laundering can distort competition, hinder economic that all business decisions and transactions that fall within development, and threaten human rights and democracy. As their area of responsibility comply with both the relevant a global player, Siemens is responsible for setting an example legal requirements and our own values and company guide- in all its operations and in collaboration with all its stake- lines. holders. By building alliances against corruption and pro- moting fair competition together with stakeholders from At Siemens, we take a zero-tolerance approach to corruption politics, business, and society, Siemens can through Collec- and other breaches of applicable laws and of our Business tive Action help establish the conditions for fair competition Conduct Guidelines (BCGs). and thereby promote innovation. Our BCGs contain the behavioral principles and rules that - Under certain circumstances, Siemens can be held liable for guide our conduct, both within Siemens and in our stake the illegal activities of third parties: for example, business holder relationships. They also serve as an expression of our partners acting as suppliers, intermediaries, resellers, and values and lay the foundation for detailed internal regula- consortium partners. Transactions conducted by business tions. The BCGs are binding for all Siemens employees partners can be misused to gain undue advantages for the around the world. business partner or for Siemens. SIEMENS SUSTAINABILITY REPORT 2023 32