The Siemens Compliance System: "Prevent - Detect - Respond and Continuous Improvement"

Josef Winter, Chief Compliance Officer (CCO), Siemens, Germany

The current Siemens Compliance System was developed in 2007 and 2008, initially in response to criminal investigations undertaken by the Office of the Public Prosecutor in Munich, the US Securities and Exchange Commission, the US Department of Justice and numerous other investigating authorities worldwide. These inquiries, as well as the independent internal investigation undertaken by US law firm Debevoise & Plimpton between January 2007 and January 2009, exposed systematic violations of anti-corruption laws and accounting regulations in many Siemens business units and Regional Companies which had been taking place over many years, as vividly described in the documents produced by the US authorities for the final judgment in the USA on December 15, 2008. It was only possible to conclude the proceedings against the company in Germany and the USA because – as explicitly stated by the US authorities – Siemens not only launched its own investigations into past malpractices and fully cooperated with public authorities, but also developed a comprehensive new Compliance System in under two years which it has implemented worldwide. The new Compliance System is based on a clearly defined system into which Siemens’ worldwide Compliance measures must fit: