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

June 2012
ComplianceIndustry

Abstract

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:

Authors

Klaus Moosmayer
Chief Compliance Officer, Siemens, Germany

Klaus Moosmayer is since January 2014 the Chief Compliance Officer of Siemens AG and head of the global Siemens Compliance Organization. Before his recent nomination he served since July 2010 as the Chief Counsel Compliance of Siemens AG and was responsible as Head of the Compliance Governance Organization for the legal Compliance management, Compliance policies, internal investigations, disciplinary sanctions, remediation and Compliance risk assessment. Since 2007 he was the Compliance Operating Officer of Siemens and had a leading role in developing the new Siemens Compliance Program reporting to the then Chief Compliance Officer. Before entering the Siemens Legal Department 2000 he was in private practice as a lawyer. He studied law at the university of Freiburg/Germany and was trained as an army officer. Klaus has published extensively to Compliance and white collar crime topics – including Compliance and Anti-Corruption Manuals for companies - and speaks frequently on national and international conferences on Compliance topics. He was appointed end of 2013 as the Anti-Corruption Chair of the Business and Industry Advisory Committee at the OECD (BIAC).

Companies

Siemens

Siemens AG

Siemens

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