FCPAméricas Blog
Siemens Speaks to FCPAméricas, Part 3: Compliance Innovations
4.10.2013
More than four years have passed since Siemens settled charges of international anti-corruption violations. Now, Siemens speaks to FCPAméricas about its experiences improving its anti-corruption compliance program. This is the third post in a three part series. See Part 1 here and Part 2 here.
In the interview, Siemens’ Deputy Head for Compliance Investigations, Mark Gough, describes several notable innovations in compliance at the company. Mr. Gough explains:
Five years ago, other companies were not too interested in what we had started doing. This changed as some of them began facing investigations from various authorities. Now there is high interest. Some have even called us the “gold standard” in compliance. I am no... Read more
Siemens Speaks to FCPAméricas, Part 2: Changing Compliance Culture at a Major Multinational
4.04.2013
More than four years have passed since Siemens settled charges of international anti-corruption violations. Now, Siemens speaks to FCPAméricas about its experiences improving its anti-corruption compliance program. This is the second post in a three part series. See Part 1 here and Part 3 here.
In the interview, Siemens’ Deputy Head for Compliance Investigations, Mark Gough, explains to FCPAméricas some of the things that the company has done to change its compliance culture, and how it can tell that the culture has changed (FCPAméricas has previously discussed these issues here).
FCPAméricas: How has your compliance program evolved since 2008?
Over the l... Read more
Siemens Speaks to FCPAméricas, Part I: Compliance Lessons after the Biggest Enforcement Action in History
4.02.2013
More than four years have passed since Siemens settled charges of international anti-corruption violations. The German engineering company still holds the record for the largest anti-bribery related penalties in history — $800 million with U.S. authorities, $800 million with German authorities, and $100 million with The World Bank. The enforcement actions were based on illicit payments made throughout the world, including Argentina, Mexico, and Venezuela.
In the years following these penalties, Siemens has very publicly engaged in a detailed (and expensive) review of its anti-corruption policies and practices. In the process, it has exemplified a mea culpa approach to responding to a compliance crisis. This is an approach that others currently under investigation and facing potentially significant penalties might want to emulate (cf. Wal-Mart, Go Big on Compliance).
Siemens’ Deputy Head for Compliance Investigations, Mark Gough, shared with FCPAméricas some of the important lessons that Siemens’ Corporate Legal and Compliance Group has learned over the last few years.
FCPAmé... Read more
