Whistleblowing and Reporting Channels

Siemens operates a corporate-wide, transparent, publicly available, and standardized complaint and reporting procedure that is fully accessible. All complaints and reports from employees or third parties are treated equally as far as legally permitted.

The complaint and reporting procedure is open to everyone: all employees and external people and organizations.

Any complaint or report of a suspected or actual violation of laws or internal regulations, including those relating to human rights and environmental risks or obligations, can be reported. The suspicion can be directed at individual Siemens employees, a Siemens business, or a Siemens supplier.

Siemens has various reporting channels for complaints or reports.

“Tell Us” is a tool to submit complaints and reports 24 hours a day, seven days a week. Complaints and reports can be in writing or by phone – and you don’t even have to give your name if you don’t want to.

“Tell Us” is available in many different languages and is managed by an independent operator. The data is stored on protected servers in Germany. The content of the complaints or reports is processed exclusively by Siemens.

An external Ombudsperson is also available. The Ombudsperson is an independent lawyer outside Siemens whom you can contact confidentially and anonymously.

If you prefer to contact someone directly at Siemens, feel free to speak to one of our Compliance Officers. You can also contact other Legal and Compliance personnel, company manager, the Human Resources department, employee representatives, or the Siemens Chief Compliance Officer.

All complaints and reports, regardless of how they were submitted, are handled by the Siemens internal investigation department, which is the company’s central “Reporting Office.” The Reporting Office reports directly to the Chief Compliance Officer, who has access to the Managing Board and the Supervisory Board of Siemens AG. Employees of the Reporting Office are subject to a special duty of confidentiality, are impartial, and have the necessary expertise to handle complaints. The company may contact you if additional information is needed, and in some instances the German Supply Chain Due Diligence Act (LkSG) requires us to discuss with you your complaint. Of course, this only works if we can contact you.

All complaints and reports are treated confidentially and may be submitted anonymously. Siemens takes great care to ensure you and your complaint or report is kept confidential and protects you as the reporter! Confidential data may only be disclosed on an as-needed basis as permitted by law. Our managers are also required to confidentially forward reports received to our Reporting Office.

Within seven days of receipt of your complaint or report, you will receive an acknowledgement of receipt from Siemens.

We take every report that comes to us seriously. The Reporting Office examines each report to determine whether the information provided requires clarification and whether there is sufficient information to do so. Sometimes, we will request additional information from you.

Once the report has been reviewed, the Reporting Office may forward the case to another responsible department within the company for processing and clarification or to a competent authority. The Reporting Office may itself handle the report or complaint. If an internal investigation is deemed necessary, an Investigation Mandate will be issued. During the investigation, the Reporting Office reviews relevant documents, speaks with witnesses and affected parties, and, if necessary, analyzes electronic data.

At the end of the clarification process, the results are summarized in a report that is distributed to relevant internal stakeholders. Results may include recommendations for disciplinary (e.g., termination, warning, transfer) or other remedial measures, including risk management and internal process measures.

Important:

All employees who participate in internal clarification must adhere to certain rules of conduct, including:

• The whistleblower must be protected! Neither names nor details may be disclosed without reason.
• Everyone must comply with the law and with Siemens internal regulations.
• Any clarification must be done fairly and with respect. All facts shall be evaluated objectively and conscientiously.
• The persons concerned have the right to be heard.
• Data and information must be treated confidentially.
• As soon as the employee notices that they have a conflict of interest, i.e., that for personal reasons it is difficult for them to conduct the clarification objectively, they must report this. The clarifying department will then transfer the case to another employee.

The Reporting Office can close the case if the report was incomplete or not comprehensible.

Insofar as it is possible and legally permissible for us to do so, we will inform the whistleblower within three months of the measures taken – even if the clarification of the facts has not been completed by then.

Siemens will not tolerate retaliation of any kind!

Persons who in good faith submit complaints or reports will not be penalized for doing. If you believe you or anyone else has been retaliated against or in any way has been treated differently for submitting a complaint or report, you should inform our company immediately through any of its reporting channels (preferably via “Tell Us“).

We follow up on all plausible allegations of retaliation or mistreatment. Substantiated retaliation by Siemens will even be punished as compliance violations.

Rechtsanwältin Dr. Sybille von Coelln

Kanzlei „HEUKING ∙ VON COELLN Rechtsanwälte“

Telefon: +49 211 44 03 57 79

Mail: siemens-ombudsfrau@hvc-strafrecht.de