Compliance

OSRAM emphasizes its responsible business conduct in every country in which we operate. Abiding by laws and official rules is a basis for successful and sustainable business. Any illegal and unlawful behavior within the company will not be tolerated. We demand from all our employees and executives to behave ethical and lawful amongst ourselves as well as externally towards our customers, partners and suppliers. To further ensure transparency, compliance must become part of our corporate culture. We herewith enter a new area of business culture . OSRAM closely coordinates its compliance and anti-corruption efforts with Siemens. This ensures a professional application within the company.

The Siemens Compliance Program

The purpose of the Siemens Compliance Program and related reporting activities is to set strict standards of integrity and transparency. Its implementation is also mandatory for OSRAM as a 100 percent Siemens affiliate. The program is divided into the following three pillars:

Prevent (compliance training, “Ask us”-Helpdesk)
Detect (“Tell us”-Helpdesk, Ombudsperson)
and Respond (consequences, if necessary legal actions taken)

For more information and details, please see the Siemens Corporate Responsibility Report 2008 (Report 2009 to be published in May 2010) and the Siemens Annual Report 2009.

More Information on the SIEMENS Website

Compliance Training

Compliance training will help all employees to critically examine certain situations occurring in their day-to-day work, and it offers practical examples to provide a basis for correct decision-making.

Helpdesk “Tell us / Ask us!” shared with Siemens

Our helpdesk offers – besides our compliance officers – the possibility for both employees and external stakeholders to report any form of noncompliance with our Business Conduct Guidelines (Tell us) or to submit questions about certain aspects regarding compliance to experts (Ask us).

External Ombudsperson

An independent ombudsman offers the possibility to report or talk about sensible compliance matters or irregular business practices in a confidential and anonymous way without having to fear reprisal. He will then pass them on to the compliance organization if suspicions turn out to be justified, strictly maintaining the anonymity of the reporting parties.

The contact details:

Attorneys Dr. Beckstein & Colleagues
Attorney Hans-Otto Jordan
Thumenberger Weg 12
90491 Nuremberg, Germany
Tel.: (+49 911) 5984020

Email: mail@siemens-ombudsmann.de

Worldwide Compliance Perception Survey

Also in 2009 OSRAM took part in the Siemens Employee Compliance Survey 2009. The survey is and remains an essential component of the Compliance Program and shows the extent to which compliance is anchored as part of the corporate culture. Compared with Siemens at 47 percent (2008: 44 percent) the level of participation at OSRAM was an excellent 60.5 percent, compared with 41 percent last year.

The results show increasing acceptance of the Compliance Program among employees. Ninety-six percent of those who took part in the survey indicated that they had a clear understanding of their own role and responsibility with regard to compliance and a positive attitude to the values of the company. The level of awareness of “Tell us,” “Ask us” and the compliance organization improved considerably compared with the previous year.

In six of seven categories OSRAM recorded a significant upward year-on-year trend. One category remained unchanged but still at a high level. And the Compliance Performance Index, which has a bearing on bonus payments for management staff, improved for OSRAM by 2 percent to 86 percent, putting it on a par with the Siemens score.

The “Compliance Communication” category showed an extremely pleasing upward trend, while the “Management Culture” category still leaves room for improvement. Only around 58 percent are impressed by the rapid decision-making of management and by successful communication “down the line.” Four of the five questions with the lowest scores come from the “Management Culture” category. Managers are therefore invited to promote this aspect and contribute to improving the overall results. The survey also showed that in all compliance-related topics the responsibilities and consequences of management are important factors in achieving even greater awareness and acceptance of compliance among employees and increasing our scores still further in the future.

Our challenge:
In 2010 we will continue to face challenges in terms of the sustainability of Compliance@OSRAM. In addition to meeting internal requirements, one of our prime objectives is to build on our leadership position in the Siemens Group through activities with an external effect.

Internal objectives:

Retention of the "Tone from the Middle" concept
Sustain a management culture characterized by openness, transparency, decisiveness and speed
Maintenance of the Compliance Controls Frameworks, which could be described as our safety net.
Continual training for our employees and managers. This year, web-based training for the Business Conduct Guidelines will play an important role.

External objectives:

All contracts with business partners must include the compliance conditions
Securing agreements with our competitors through our industry associations about fair market conditions as part of collective actions.
Reaching agreements with joint venture partners to achieve concrete improvements in certain companies in which we have a minority shareholding and which have compliance standards that do not yet meet our requirements.