Our Compliance System
As a publicly listed independent company of the Siemens group, we implemented the Compliance System of Siemens AG worldwide in all our entities. Because for us it is also true: Only clean business is Siemens Healthineers business!
Our Legal & Compliance organization is directly accountable to the CEO of Siemens Healthineers AG, and reports to the Managing Board as well as to the Supervisory Board on a regular basis.
What does Compliance stand for at Siemens Healthineers?
We do not tolerate any kind of bribery, any violation of competition and antitrust laws, nor any violation of data privacy rights. At the same time, we work to ensure that third parties will not misuse our business for money laundering. Together with our partners worldwide we foster transparency and fairness within the healthcare industry in Collective Action projects. We adhere to export control and customs regulations and respect human rights.
What are the components of the Compliance System at Siemens Healthineers?
Our Compliance System is composed of three operating levels: Prevent, Detect, and Respond.
We focus on preventive measures like information, training, and clear regulations which are valid for everybody. Essential business transactions are reviewed thoroughly with regard to Compliance risks, prior to execution. Should there still be violations of applicable law, we will investigate the circumstances comprehensively in a fair procedure and then take appropriate disciplinary measures, as deemed necessary. The basic principle behind your reaction to each identified violation is: Every employee and manager is treated equally and recognized weak spots in the system will be remediated.
The heart and soul of our Compliance System are the Business Conduct Guidelines, which establish the binding rules of conduct for all employees towards each other as well as towards the integrity of our business. One of our guiding principles is: We don´t compromise on quality. This is valid not only in relation to the quality of our products and services, but relates to everything we do. Quality is first and foremost affected through the adherence to rules and norms as well as the highest standards. This is also true for Compliance. All Siemens Healthineers, whether employee or manager, have to understand Compliance as part of their own tasks; with management bearing the responsibility for the correct conduct of the team members.
The same standards that we adhere to are also valid for our business partners in sales, procurement, and production.
We fight corruption collectively, working together with various interest groups to build an alliance against corruption. We approach and resolve the problem from multiple angles with the ultimate goal of creating fair and equal market conditions – a "level playing field" – for all market players and eliminating the temptations of corruption for all.
Collective Action at Siemens Healthineers aims to bring more opportunities to cooperate with alliances in the healthcare industry, to improve the compliance environment, and to benefit all – not only market players, but also healthcare professionals and patients. We do this for example by being a member of the trade association MedTech Europe and actively working on the MedTech Europe Code of Ethical Business Practice.
Business Conduct Guidelines
The Business Conduct Guidelines 3.2 MB set the ethical and legal framework, within which we intend to act and stay successful. They contain the basic principles and rules for the conduct of all employees and managers within the company as well as in relation to our external partners and the general public.
The Business Conduct Guidelines will adapt to new legal regulations and are aligned with international treaties regarding human rights, the fight against corruption, as well as sustainability. All employees are called upon to adhere to the Business Conduct Guidelines and to live them actively.
Business Partners & Suppliers
We work with partners like sales agents, distributors, and customs agents globally to sell products and services. We also cooperate with other kind of partners like consultants, or partners in joint ventures or consortia. Our aim is to make sure that all our partners work with a high level of transparency and integrity comparable to ours. Therefore we carefully select our partners and achieve transparency through a due diligence check followed by continuous training and monitoring. Our company-wide established internal Business Partner Tool helps ensure that all processes are implemented and lived without exception.
Code of Conduct for Suppliers of Siemens Healthineers
We want to be an integral part of the national society and economy in all countries. In daily business this represents a challenge due to the varying regulatory environments we operate in. That is why we developed a Code of Conduct for our suppliers. In essence, the Code of Conduct for suppliers to Siemens Healthineers is based on the UN Global Compact and the principles of the International Labor Organization and is also reflected in our Business Conduct Guidelines, which are binding for all employees of Siemens Healthineers.
The topics of the Code of Conduct are:
- Compliance with the laws of the applicable legal system
- Prohibition of corruption and bribery
- Fair competition, anti-trust laws, and intellectual property rights
- Avoidance of conflicts of interest
- Respect for the basic human rights of employees
- Prohibition of child labor
- Health and safety of employees
- Environmental protection
- Promotion of the Code of Conduct among further suppliers in the supply chain and no discrimination in supplier selection and treatment
- Responsible minerals sourcing
Channels for Reporting Misconduct
Reliable reporting channels for internal and external stakeholders and the protection of internal whistle-blowers from sanctions help ensure that possible misconduct is reported, thoroughly investigated, and clarified. We provide several reporting channels to internal and external whistle-blowers to inform us about possible compliance violations.
Let Us Know reporting system
Let Us Know provides a secure channel for reporting non-compliant or otherwise problematic actions 24 hours a day: online, anonymously if desired, and in several languages. We protect the identity of whistleblowers and follow-up on these reports.
The Siemens Healthineers Ombudswoman
In addition, attorney-at-law Dr. Sibylle von Coelln (homepage in German only), from the Duesseldorf-based law firm HEUKING·VON COELLN, has been appointed as our external ombudswoman. Employees and third parties can confidentially and anonymously confide in this impartial professional should they observe improper business practices in the company.